Case: Chapman v. Rhodes

1:75-00251 | U.S. District Court for the Southern District of Ohio

Filed Date: July 8, 1978

Closed Date: 1981

Clearinghouse coding complete

Case Summary

In 1975, two inmates at the Southern Ohio Correctional Facility filed a lawsuit, pro se, under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Ohio against officials of the Ohio State Prison system. Certification as a class action was originally denied on the ground that the asserted representatives were not qualified to represent the claimed class. After the American Civil Liberties Union entered appearances on behalf of the plaintiffs, the case was certified as a cla…

In 1975, two inmates at the Southern Ohio Correctional Facility filed a lawsuit, pro se, under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Ohio against officials of the Ohio State Prison system. Certification as a class action was originally denied on the ground that the asserted representatives were not qualified to represent the claimed class. After the American Civil Liberties Union entered appearances on behalf of the plaintiffs, the case was certified as a class action. Plaintiffs alleged that defendants' practice of double celling, whereby two inmates were housed in a single cell, constituted cruel and unusual punishment in violation of the Eighth Amendment.

On June 29, 1977, the District Court (Chief Judge Timothy Sylvester Hogan) held that although housing two inmates in one cell was not unconstitutional per se, the limited amount of square-footage provided to prisoners at Southern Ohio Correctional Facility rendered double-celling under the circumstances unconstitutional. Chapman v. Rhodes, 434 F. Supp. 1007 (S.D. Ohio 1977). Judge Hogan ordered defendants to produce a plan within 90 days that would terminate double celling at Southern Ohio Correctional Facility. Defendants appealed and on June 6, 1980, the Sixth Circuit affirmed without opinion. Chapman v. Rhodes, 624 F.2d 1099 (6th Cir. 1980). The Supreme Court granted certiorari and the plaintiffs' motions to proceed in forma pauperis. Rhodes v. Chapman, 449 U.S. 951 (1980).

The Supreme Court (Justice Lewis Franklin Powell) reversed. Rhodes v. Chapman, 452 U.S. 337 (1981). Writing for the majority, Justice Powell held that double celling at the prison did not violate the Eighth Amendment, noting that despite the fact that prisoners were serving long sentences, that double-celling wasn't temporary, that the prison was over capacity, and that prisoners spent much time in the cells with their cellmates, the conditions of double-celling were nevertheless insufficient to constitute cruel and unusual punishment. Justices Brennan and Blackmun filed concurring opinions, and Justice Marshall filed a dissenting opinion in the case.

Summary Authors

Eoghan Keenan (6/10/2005)

People


Judge(s)

Hogan, Timothy Sylvester (Ohio)

Powell, Lewis Franklin Jr. (District of Columbia)

Attorneys(s) for Plaintiff

App, Robert P. (Ohio)

Barrows, Edward Clark (Ohio)

Friedman, Bruce (Ohio)

Jacobs, Louis A. (Ohio)

Kamp, Jean P. (Ohio)

Leventer, Jan (Ohio)

Rosenberg, Howard J. (Ohio)

Stanley, Christopher D. (Ohio)

Judge(s)

Hogan, Timothy Sylvester (Ohio)

Powell, Lewis Franklin Jr. (District of Columbia)

Attorneys(s) for Plaintiff

App, Robert P. (Ohio)

Barrows, Edward Clark (Ohio)

Friedman, Bruce (Ohio)

Jacobs, Louis A. (Ohio)

Kamp, Jean P. (Ohio)

Leventer, Jan (Ohio)

Rosenberg, Howard J. (Ohio)

Stanley, Christopher D. (Ohio)

Twohig, R. Raymond Jr. (New Mexico)

Attorneys(s) for Defendant

Adler, Allen Paul (Ohio)

Conway, Leo J. (Ohio)

Documents in the Clearinghouse

Document

Findings of Fact and Conclusions of Law

434 F.Supp. 1007

June 29, 1977 Order/Opinion

Memorandum Decision

U. S. Court of Appeals for the Sixth Circuit

624 F.2d 1099

June 6, 1980 Order/Opinion

Memorandum Decision

Rhodes v. Chapman

Supreme Court of the United States

449 U.S. 951, 101 S.Ct. 353, 66 L.Ed.2d 214

Nov. 3, 1980 Order/Opinion

[Granting motion not to supplement Joint Appendix]

Rhodes v. Chapman

Supreme Court of the United States

449 U.S. 1060

Dec. 15, 1980 Order/Opinion

Supreme Court Decision

Rhodes v. Chapman

Supreme Court of the United States

449 U.S. 1122

Jan. 26, 1981 Order/Opinion

Supreme Court Decision

Rhodes v. Chapman

Supreme Court of the United States

450 U.S. 906

Feb. 23, 1981 Order/Opinion

Memorandum Decision

Rhodes v. Chapman

Supreme Court of the United States

452 U.S. 337, 101 S.Ct. 2392, 69 L.Ed.2d 59

June 15, 1981 Order/Opinion

Resources

Title Description External URL

The Oyez Project, Rhodes v Chapman, 452 U.S. 337 (1981)

Oyez Project

Information about the Supreme Court litigation in this case, including an audio recording of the oral argument, and the written opinion. June 15, 1981 http://www.oyez.org/cases/1980-1989/1980/1980_80_332/

Rhodes v. Chapman Analyzed for Effect on Prison Overcrowding

Michael B. Mushlin

Dec. 1, 1987

Hard Judicial Choices: Federal District Court Judges and State and Local Officials

Phillip J. Cooper

March 17, 1988

Docket

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

Docket sheet not available via the Clearinghouse.

State / Territory: Ohio

Case Type(s):

Prison Conditions

Key Dates

Filing Date: July 8, 1978

Closing Date: 1981

Case Ongoing: No

Plaintiffs

Plaintiff Description:

inmates in the Ohio correctional system

Public Interest Lawyer: Yes

Filed Pro Se: Yes

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Ohio Department of Correcctions, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Availably Documents:

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1977 - 1977

Issues

General:

Assault/abuse by residents/inmates/students

Classification / placement

Food service / nutrition / hydration

Law library access

Recreation / Exercise

Sanitation / living conditions

Visiting

Crowding:

Crowding / caseload

Affected Gender:

Male

Type of Facility:

Government-run