Case: U.S. v. Michigan

1:84-cv-00063 | U.S. District Court for the Western District of Michigan

Filed Date: Jan. 18, 1984

Closed Date: 1999

Clearinghouse coding complete

Case Summary

On January 18, 1984, the U.S. Attorney's Office and the Department of Justice filed suit in the U.S. District Court for the Western District of Michigan against the Michigan Department of Corrections and other state officials under 42 U.S.C. §1983 and the Civil Rights of Institutionalized Persons Act (CRIPA), 42 U.S.C. §1997, alleging unconstitutional prison conditions. The United States sought injunctive relief to remedy the alleged Eighth Amendment violations. Shortly after the lawsuit was fi…

On January 18, 1984, the U.S. Attorney's Office and the Department of Justice filed suit in the U.S. District Court for the Western District of Michigan against the Michigan Department of Corrections and other state officials under 42 U.S.C. §1983 and the Civil Rights of Institutionalized Persons Act (CRIPA), 42 U.S.C. §1997, alleging unconstitutional prison conditions. The United States sought injunctive relief to remedy the alleged Eighth Amendment violations.

Shortly after the lawsuit was filed, the parties entered into a consent decree, which included a compliance plan dealing with conditions of confinement such as medical and mental health care, fire safety, sanitation, hygiene, crowding and protection from harm. The District Court (Judge Richard Alan Enslen) appointed Special Master F. Warren Benton to oversee implementation of the plan on October 2, 1985. The District Court continued to issue various orders to ensure implementation of the consent decree, and on August 28, 1987, Judge Enslen granted the National Prison Project of the American Civil Liberties Union amicus status. U.S. v. State of Michigan, 116 F.R.D. 655 (W.D.Mich. 1987). On March 3, 1988, Judge Enslen held that a policy permitting use of food loaf as punishment even when the misconduct charge upon which that punishment was based had been dismissed violated due process rights. U.S. v. State of Michigan, 680 F.Supp. 270 (W.D.Mich. 1988). A helpful compilation of the opinions and orders issued in the case through July 1987 was published in U.S. v. State of Michigan, 680 F.Supp. 928 (W.D.Mich. 1988).

On July 2, 1991, after state defendants appealed orders issued by Judge Enslen to implement the consent decree, the U.S. Court of Appeals for the Sixth Circuit (Judge Robert B. Krupansky) held that the District Court had abused its discretion. U.S. v. State of Michigan, 940 F.2d 143 (6th Cir. 1991). The Court of Appeals found that Judge Enslen had overly intruded upon Michigan's sovereignty. The Court of Appeals ordered Judge Enslen to not impose upon the state overly intrusive remedies for prison conditions but instead to exercise restraint and reason in performing the District Court's oversight responsibility.

The state defendants appealed a subsequent order by Judge Enslen denying the defendants' motion to dismiss portions of the consent decree. On March 4, 1994, the Court of Appeals (Judge James L. Ryan) upheld Judge Enslen's decision to dismiss only those portions of the consent decree where compliance had been achieved. U.S. v. State of Michigan, 18 F.3d 348 (6th Cir. 1994), cert. denied 513 U.S. 925 (1994). On August 7, 1995, the Court of Appeals (Judge Herbert Theodore Milburn) upheld various orders issued by Judge Enslen regarding the provision of mental health beds but held that the District Court lacked jurisdiction to modify its orders of September 1994 while those orders were on appeal. U.S. v. State of Michigan, 62 F.3d 1418 (6th Cir. 1995) (unpublished disposition).

Following passage of the Prison Litigation Reform Act (PLRA), 18 U.S.C. §3626, the state defendants moved for immediate termination of the consent decree because no findings of liability were made in the case, as it was initially resolved by a consent decree. The state defendants also invoked the PLRA's automatic stay provision, to stay prospective relief. On July 3, 1996, the Court of Appeals ordered that the motion for immediate termination be denied, ruling that the termination motion was more properly addressed to the District Court. U.S. v. State of Michigan, 91 F.3d 145 (6th Cir. 1996) (unpublished table disposition). On the same date as the Court of Appeals decision, July 3, 1996, the District Court (Chief Judge Enslen) ordered that the District Court was incapable of reaching a decision on the motion to terminate before the automatic stay provision would take effect and further held that the automatic stay provision was unconstitutional. U.S. v. State of Michigan, 989 F.Supp. 853 (W.D.Mich. 1996). Thus, Chief Judge Enslen utilized a different PLRA provision, 18 U.S.C. §3626(b)(3), to hold that the automatic stay provision was not to take effect until further evidentiary hearings were conducted regarding the state defendants' motion to terminate.

On September 12, 1996, Chief Judge Enslen granted the plaintiff's discovery motion to conduct further fact-finding and stated that recent hearings revealed ongoing constitutional violations regarding the mental health care of inmates. The state defendants appealed this ruling, and on January 14, 1998, the Court of Appeals dismissed the appeal for lack of jurisdiction because the District Court's discovery order was not a final order nor was it property appealable as an interlocutory order. U.S. v. State of Michigan, 134 F.3d 745 (6th Cir. 1998) (per curiam). The Court of Appeals (Judge Karen Nelson Moore) then held in a related case on May 20, 1998, that the automatic stay provision of the PLRA was constitutional when construed to permit the District to retain its equitable power to suspend the stay in accordance with general equitable principles. Hadix v. Johnson, 144 F.3d 925 (6th Cir. 1998) (PC-MI-0003).

On February 3, 1999, Chief Judge Enslen granted the parties' joint motion to terminate the consent decree pursuant to the PLRA. The case is closed.

Summary Authors

Tom Madison (10/18/2006)

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Hadix v. Caruso, Western District of Michigan (1992)

Hadix v. Johnson, Western District of Michigan (1992)

People


Judge(s)

Beckwith, Sandra Shank (Ohio)

Boggs, Danny Julian (Kentucky)

Celebrezze, Anthony Joseph (Ohio)

Daughtrey, Martha Craig (Tennessee)

Enslen, Richard Alan (Michigan)

Guy, Ralph B. Jr. (Michigan)

Johnstone, Edward Huggins (Kentucky)

Keith, Damon Jerome (Michigan)

Krupansky, Robert B. (Ohio)

Milburn, Herbert Theodore (Tennessee)

Judge(s)

Beckwith, Sandra Shank (Ohio)

Boggs, Danny Julian (Kentucky)

Celebrezze, Anthony Joseph (Ohio)

Daughtrey, Martha Craig (Tennessee)

Enslen, Richard Alan (Michigan)

Guy, Ralph B. Jr. (Michigan)

Johnstone, Edward Huggins (Kentucky)

Keith, Damon Jerome (Michigan)

Krupansky, Robert B. (Ohio)

Milburn, Herbert Theodore (Tennessee)

Norris, Alan Eugene (Ohio)

Ryan, James Leo (Michigan)

Suhrheinrich, Richard Fred (Michigan)

Thomas, William Kernahan (Ohio)

Attorneys(s) for Plaintiff

Alexander, Elizabeth R. (District of Columbia)

Campanelli, Richard (District of Columbia)

Carle, Susan D. (District of Columbia)

Curry, John J. jr. (District of Columbia)

Dunne, John R. (District of Columbia)

Fette, William L. (Michigan)

Flynn, David K. (District of Columbia)

Granholm, Jennifer M. (Michigan)

Guzman, Philip A. (District of Columbia)

Joyce, Patrick M. (District of Columbia)

Lawrence, Paul S. (District of Columbia)

McElderry, Marie K. (District of Columbia)

Payne, Timothy R. (District of Columbia)

Peabody, Arthur E. Jr. (District of Columbia)

Reynolds, William Bradford (District of Columbia)

Russell, Joann M. (District of Columbia)

Smietanka, John A. (Michigan)

Smith, William French (District of Columbia)

Stark, Lisa J. (District of Columbia)

Weinstein, Laurie J. (District of Columbia)

Attorneys(s) for Defendant

Adams, Richard M.C. (Michigan)

Barnhart, Timothy (Michigan)

Barrick, Andrew J. (District of Columbia)

Cahill, John M. (California)

Friedman, Leo H. (Michigan)

Gilman, Leonard R. (Michigan)

Kelley, Frank J. (Michigan)

MacKenzie, Brian W. (Michigan)

McGehee, Donald S. (Michigan)

Moquin, Michael J. (Michigan)

Nelson, Thomas C. (Michigan)

Nickerson, Michael A. (Michigan)

Przekop-Shaw, Susan (Michigan)

Przeko-Shaw, Susan (Michigan)

Quinn, Andrew D. (Michigan)

Schmidt, Barbara A. (Michigan)

Steinborn, Stanley D. (Michigan)

Streeter, Patricia A. (Michigan)

Van Cleve, Janet A. (Michigan)

Ward, Lisa C. (Michigan)

Other Attorney(s)

Aiyetoro, Adjoa A. (District of Columbia)

Bennett, Larry W. (Michigan)

Blake, Patricia L. (Michigan)

Gershal, Alan M. (Michigan)

Gowing, Delmer C. III (Florida)

Miaskoff, Carol R. (District of Columbia)

Pawlowski, George E. (Michigan)

Taifa-Caldwell, Nkechi (District of Columbia)

Expert/Monitor/Master

Benton, F. Warren (New York)

Dettmer, Michael Hayes (Michigan)

Rosenbaum, Steven H. (District of Columbia)

Documents in the Clearinghouse

Document

Docket (PACER)

Nov. 24, 2003 Docket

Complaint

Dec. 15, 1983 Complaint

Consent Decree

June 28, 1984 Order/Opinion

Brief in Support of Appointment of Special Master

July 5, 1985 Pleading / Motion / Brief

Response to Defendants Request for Modification of the State Plan

Oct. 10, 1986 Pleading / Motion / Brief

Compilation of Opinions and Orders

680 F.Supp. 928

July 27, 1987 Order/Opinion

Opinion

116 F.R.D. 655

Aug. 28, 1987 Order/Opinion

Opinion

680 F.Supp. 270

March 3, 1988 Order/Opinion

Order

April 24, 1989 Order/Opinion
877

Order

Nov. 6, 1989 Order/Opinion

Resources

Title Description External URL

Sexual Violence as an Occupational Hazard & Condition of Confinement in the Closed Institutional Systems of the Military and Detention

Hannah Brenner, Kathleen Darcy & Sheryl Kubiak

Women in the military are more likely to be raped by other service members than to be killed in combat. Female prisoners internalize rape by corrections officers as an inherent part of their sentence… Jan. 1, 2017 https://digitalcommons.pepperdine.edu/cgi/viewcontent.cgi?article=2452&context=plr

Docket

Last updated May 13, 2022

Docket sheet not available via the Clearinghouse.

State / Territory: Michigan

Case Type(s):

Prison Conditions

Key Dates

Filing Date: Jan. 18, 1984

Closing Date: 1999

Case Ongoing: No

Plaintiffs

Plaintiff Description:

United States Department of Justice

Plaintiff Type(s):

U.S. Dept of Justice plaintiff

Attorney Organizations:

ACLU National (all projects)

ACLU National Prison Project

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Charles Egeler Facility, State

Parnall Correctional Facility, State

Marquette Branch Prison (Marquette), State

Michigan Reformatory (Ionia), State

State Prison of Southern Michigan (Jackson), State

Case Details

Causes of Action:

42 U.S.C. § 1983

Civil Rights of Institutionalized Persons Act (CRIPA), 42 U.S.C. § 1997 et seq.

Constitutional Clause(s):

Cruel and Unusual Punishment

Availably Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1984 - 1999

Issues

General:

Bathing and hygiene

Fire safety

Food service / nutrition / hydration

Personal injury

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Totality of conditions

Crowding:

Crowding / caseload

Medical/Mental Health:

Medical care, general

Mental health care, general

Type of Facility:

Government-run