Case: Hines v. Anderson

4:73-cv-00387 | U.S. District Court for the District of Minnesota

Filed Date: Aug. 7, 1973

Closed Date: 2007

Clearinghouse coding complete

Case Summary

In August 1973, inmates at the Minnesota State Prison filed this class action lawsuit in the District of Minnesota against the Minnesota State Prison and all related officials. The plaintiffs, represented by private counsel, sued under 42 U.S.C. § 1983 and claimed that the medical care and facilities at the Minnesota State Prison were inadequate, in violation of the Eighth and Fourteenth Amendments. In May 1977, the District Court (Judge Earl R. Larson) accepted a consent agreement reached by t…

In August 1973, inmates at the Minnesota State Prison filed this class action lawsuit in the District of Minnesota against the Minnesota State Prison and all related officials. The plaintiffs, represented by private counsel, sued under 42 U.S.C. § 1983 and claimed that the medical care and facilities at the Minnesota State Prison were inadequate, in violation of the Eighth and Fourteenth Amendments.

In May 1977, the District Court (Judge Earl R. Larson) accepted a consent agreement reached by the parties and entered a consent decree establishing guidelines for the provision of medical care and treatment for inmates in the Minnesota State Prison. The consent decree required that, with respect to the primary maximum security prison for men in Minnesota, the applicable state law (commonly known as the "Patients Bill of Rights") would apply to the fullest extent possible to inmates requiring medical treatment. The decree required that no inmate be deprived of medical care, medication, or prosthetic devices due to indigence. Additionally, the decree required that the prison have a full-time physician and medical staff on daily, weekend, and "on-call" duty. The Court retained jurisdiction for oversight of the consent decree's implementation. The District Court also granted class certification for a class of “all inmates of the Minnesota State Prison who are now or may in the future be in the need of medical care, including examination, diagnosis or treatment, while so confined.” 439 F. Supp. 12.

The decree was limited to the "primary maximum security prison for men in Minnesota.” Initially it applied to the Minnesota State Prison in Bayport, Minnesota, but from 1999 onward applied only to the Minnesota Correctional Facility at Oak Park Heights. Although the original paper docket for this case is unavailable, the available PACER docket indicates that from 1996 until 2002, several individual inmates made repeated motions for contempt, all of which were denied without prejudice by the District Court (Judge Michael J. Davis).

In August 2002, the defendants moved to terminate the consent decree under the Prison Litigation Reform Act pursuant to § 3626(b). The Prison Litigation Reform Act, enacted by Congress in 1996, outlined appropriate remedies in civil litigation regarding prison conditions. Section 3626(b) addressed the termination of relief and applied retroactively to prospective relief that was entered before the statute's enactment. Initially, the District Court denied the defendant's motion without prejudice, reasoning that the Court lacked subject matter jurisdiction over the motion. However, the Eighth Circuit Court of Appeals (Judges Roger L. Wollman, George G. Fagg, and Morris S. Arnold) reversed and remanded, finding that a case or controversy existed. 83 Fed. Appx. 148.

In November 2004, Magistrate Judge Arthur J. Boylan issued a report and recommendation that the district court grant the defendants’ motion to terminate the decree. After reviewing the plaintiffs’ objections, the District Court granted the plaintiffs leave to engage in additional discovery for the purpose of presenting evidence of ongoing Eighth Amendment violations at the Oak Park Heights Facility.

Following discovery, both parties submitted supplemental memorandums and exhibits with respect to the motion to terminate the decree. The plaintiffs filed a report prepared by their expert, and individual inmates filed numerous submissions regarding the alleged inadequacies of their medical care. In turn, the defendants submitted the medical records pertaining to those individuals. The matter was again submitted to Magistrate Judge Boylan for review, and in January 2007, he issued another report and recommendation. The report found that neither the plaintiffs’ declarations nor their expert submissions supported the plaintiffs’ argument that there were current and ongoing Eighth Amendment violations. The report further found that the decree was not narrowly constructed and that its provisions addressed issues that were ancillary to core Eighth Amendment medical treatment issues. The report concluded by recommending that the decree be terminated. After conducting a de novo review, the District Court adopted the report’s recommendation and denied the plaintiffs’ request for further discovery and an evidentiary hearing.

The plaintiffs appealed this decision, and on November 21, 2008, the Court of Appeals (Judges Roger L. Wollman, C. Arlen Beam, and Kermit E. Bye) affirmed the District Court decision. The Court found that neither the Due Process Clause nor the Prisoner Litigation Reform Act entitled the plaintiffs to further discovery or an evidentiary hearing because a consent decree is not a final judgment and thus the plaintiffs did not have a vested property interest in the decree. The Court also held that the plaintiffs had failed to show that the defendants’ failure to provide medical care to prisoners amounted to an Eighth Amendment violation. Finally, the Court upheld the District Court’s finding that the consent decree was not narrowly drawn. 547 F.3d 915. The case was closed in March 2007.

Summary Authors

Kristen Sagar (8/2/2007)

Sara Stearns (7/1/2019)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/4672110/parties/hines-v-anderson/


Judge(s)

Arnold, Richard Sheppard (Arkansas)

Beam, Clarence Arlen (Nebraska)

Boylan, Arthur J. (Minnesota)

Bye, Kermit Edward (North Dakota)

Davis, Michael James (Minnesota)

Fagg, George Gardner (Iowa)

Larson, Earl Richard (Minnesota)

Schiltz, Patrick Joseph (Minnesota)

Wollman, Roger Leland (South Dakota)

Attorneys(s) for Plaintiff

Cullen, James P. (Minnesota)

Judge(s)

Arnold, Richard Sheppard (Arkansas)

Beam, Clarence Arlen (Nebraska)

Boylan, Arthur J. (Minnesota)

Bye, Kermit Edward (North Dakota)

Davis, Michael James (Minnesota)

Fagg, George Gardner (Iowa)

Larson, Earl Richard (Minnesota)

Schiltz, Patrick Joseph (Minnesota)

Wollman, Roger Leland (South Dakota)

Attorneys(s) for Plaintiff

Cullen, James P. (Minnesota)

Vasaly, Mary Ruth (Minnesota)

Attorneys(s) for Defendant

Jensen, Thomas H. (Minnesota)

Lockhart, Greer E. (Minnesota)

Service, Jennifer A. (Minnesota)

Expert/Monitor/Master

Nearing, Carolin J. (Minnesota)

Documents in the Clearinghouse

Document

4:73-cv-00387

Docket (PACER)

May 4, 2012

May 4, 2012

Docket

4:73-cv-00387

Order and Consent Decree

May 27, 1977

May 27, 1977

Order/Opinion

03-02010

Opinion

U. S. Court of Appeals for the Eighth Circuit

Dec. 15, 2003

Dec. 15, 2003

Order/Opinion
802

4:73-cv-00387

Report and Recommendation on Motion to Terminate Consent Decree

Jan. 29, 2007

Jan. 29, 2007

Order/Opinion
807

4:73-cv-00387

Order Terminating Consent Decree

March 30, 2007

March 30, 2007

Order/Opinion

07-02102

Opinion

U. S. Court of Appeals for the Eighth Circuit

Nov. 21, 2008

Nov. 21, 2008

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4672110/hines-v-anderson/

Last updated Sept. 4, 2022, 3:12 a.m.

ECF Number Description Date Link Date / Link
736

ORDER affirming 730 Magistrate Judge Boylan's Order dated August 19, 2005(Written Opinion). Signed by Judge Michael J Davis on 09/26/2005. (SMS)

Sept. 26, 2005

Sept. 26, 2005

RECAP

Case Details

State / Territory: Minnesota

Case Type(s):

Prison Conditions

Key Dates

Filing Date: Aug. 7, 1973

Closing Date: 2007

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Prisoners at the Minnesota State Prison

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Minnesota State Prison, State

Governor of State of Minnesota, State

Defendant Type(s):

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Availably Documents:

Trial Court Docket

Injunctive (or Injunctive-like) Relief

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1977 - 2007

Issues

General:

Conditions of confinement

Confidentiality

Counseling

Food service / nutrition / hydration

Staff (number, training, qualifications, wages)

Medical/Mental Health:

Medical care, general

Medication, administration of

Type of Facility:

Government-run