Case: Walker v. Johnson

4:81-40336 | U.S. District Court for the Eastern District of Michigan

Filed Date: June 19, 1981

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Case Summary

In 1981, a group of incarcerated persons brought this class action suit in the U.S. District Court for the Eastern District of Michigan against the State of Michigan; the Michigan Department of Corrections; and the wardens of Marquette Branch Prison, the State Prison of Southern Michigan, and the Michigan Reformatory at Ionia. The suit alleged that a lockdown imposed by prison officials in response to riots severely restricted the privileges afforded to incarcerated individuals and resulted in …

In 1981, a group of incarcerated persons brought this class action suit in the U.S. District Court for the Eastern District of Michigan against the State of Michigan; the Michigan Department of Corrections; and the wardens of Marquette Branch Prison, the State Prison of Southern Michigan, and the Michigan Reformatory at Ionia. The suit alleged that a lockdown imposed by prison officials in response to riots severely restricted the privileges afforded to incarcerated individuals and resulted in conditions of confinement that violated their First, Eighth, and Fourteenth Amendment rights. The plaintiff class consisted of all present and future incarcerated persons at all three institutions. Represented by private counsel, the plaintiffs sought injunctive relief requiring the defendants to restore prison conditions to the pre-riot level. The case was assigned to District Judge Stewart A. Newblatt.

In late May of 1981, correctional officers at the State Prison of Southern Michigan attempted to lock down the prison against the orders of the warden. A riot broke out in response to the attempted lockdown and shortly spread to the Marquette Branch Prison and the Michigan Reformatory at Ionia. Prison authorities resumed control of all three institutions within five days and thereafter imposed a new set of restrictions that led to the filing of this suit. The incarcerated plaintiffs sought to challenge their conditions of confinement as well as the Michigan Department of Corrections rule that allowed an institution to assign an incarcerated person to administrative segregation merely upon the finding that they had committed a major misconduct violation.

A seven-week trial took place before the district court in the fall of 1981. The court identified a number of post-riot restrictions at all three institutions: yard time was reduced for all incarcerated people (many from eight hours down to one hour) and recreational activities were significantly restricted; shower allowances were cut for most people, with some compelled to forego yard time or a meal in order to shower, while others were required to walk naked to and from the showers; group religious services were limited or eliminated entirely; the number of people involved in either work or school assignments fell significantly; access to the law library and jailhouse lawyers was severely restricted; and some people had their monthly visitations reduced from six to five.

On June 21, 1982, Judge Newblatt issued an opinion identifying a due process violation, as well as a number of constitutional violations as to the conditions of confinement. With respect to administrative segregation assignments, the district court ordered the defendants to conduct a hearing with 24-hour notice provided to the incarcerated individual, allow the individual to call witnesses and produce documentary evidence, and produce a written statement setting out the reason behind any decision to impose an administrative segregation sanction. The court further ordered that the institutions increase yard time for all incarcerated persons; cease requiring incarcerated people to walk naked to and from showers; increase shower allotments for some incarcerated individuals and schedule showers such that they were not a forced substitute for yard time; increase law library access and, in some cases, restore it to the pre-riot level; and allow for a minimum level of group religious activities. Walker v. Johnson, 544 F.Supp. 345.

The defendants appealed the ruling to the United States Court of Appeals for the Sixth Circuit. In August of 1985, a panel consisting of Circuit Judges Harry W. Wellford, Herbert Theodore Milburn and District Judge Joseph Peter Kinneary affirmed in part, reversed in part, and remanded in part the district court’s ruling in the class action. Walker v. Mintzes, 771 F.2d 920. The court of appeals questioned the district court's imposition of specific yard time requirements for each prison and remanded this issue for clarification. The court also remanded the issue of religious services because the district court had failed to consider the state's security and disciplinary interests during the emergency lockdown. The court reversed the district court's order as to law library access and remanded for a specific finding of whether access to the courts had been denied to any individual. The lower court's rulings as to shower allotments and the walk to and from showers and as to the due process rights of incarcerated persons in administrative segregation were affirmed.

We have no further information as to the findings of the district court on remand, nor do we know the final disposition of this case. Several incarcerated people affected by the 1981 lockdown later filed successful damages actions. Those cases can be found at: In re Jackson Lockdown/MCO Cases.

Summary Authors

Megan Raynor (4/17/2006)

Rachel Harrington (3/13/2022)

Related Cases

In re Jackson Lockdown/MCO Cases, Eastern District of Michigan (1981)

People


Judge(s)

Newblatt, Stewart Albert (Michigan)

Wellford, Harry Walker (Tennessee)

Attorneys(s) for Plaintiff

Bennett, Larry W. (Michigan)

Bush, Neal (Michigan)

Goodman, William Harry (Michigan)

Grenzotto, Mark (Michigan)

Magid, Judith E. (Michigan)

Attorneys(s) for Defendant

Kelley, Frank J. (Michigan)

McKenzie, Brian (Michigan)

Nelson, Thomas C. (Michigan)

Judge(s)

Newblatt, Stewart Albert (Michigan)

Wellford, Harry Walker (Tennessee)

Attorneys(s) for Plaintiff

Bennett, Larry W. (Michigan)

Bush, Neal (Michigan)

Goodman, William Harry (Michigan)

Grenzotto, Mark (Michigan)

Magid, Judith E. (Michigan)

Attorneys(s) for Defendant

Kelley, Frank J. (Michigan)

McKenzie, Brian (Michigan)

Nelson, Thomas C. (Michigan)

Documents in the Clearinghouse

Document

Memorandum Opinion and Order

544 F.Supp. 345

June 21, 1982 Order/Opinion

Reported Opinion

Walker v. Mintzes

U. S. Court of Appeals for the Sixth Circuit

771 F.2d 920

Aug. 22, 1985 Order/Opinion

Resources

Title Description External URL

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: Michigan

Case Type(s):

Prison Conditions

Key Dates

Filing Date: June 19, 1981

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

all present and future inmates at Marquette Branch Prison, State Prison of Southern Michigan, and Michigan Reformatory at Ionia

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Michigan Department of Corrections , State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Equal Protection

Free Exercise Clause

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Issues

General:

Access to lawyers or judicial system

Administrative segregation

Disciplinary procedures

Food service / nutrition / hydration

Law library access

Recreation / Exercise

Religious programs / policies

Visiting

Type of Facility:

Government-run