Case: Adams & U.S. v. Mathis

On November 19, 1974, an inmate of the Houston County Jail in Alabama filed this case, pro se, in the United States District Court for the Middle District of Alabama, seeking class action status. He proceeded under 42 U.S.C. § 1983 against State officials responsible for the jail, challenging many aspects of conditions--overcrowding, poor sanitation, inadequate nutrition, medical care, and recreational opportunities. The case was assigned to Judge Frank Johnson.

The United States became involved when Judge Johnson appointed the United States Attorney as amicus curiae. According to a later opinion, this order was "entered on the basis of allegations in the complaint concerning interference with the mail to and from the District Court and also on the basis of a contract between the United States and Houston County to house federal prisoners in the Houston County Jail." Adams v. Mathis, 458 F.Supp. 302 (M.D. Ala., 1978) In March 1975, the United States moved to intervene in the action and filed a complaint in intervention. The complaint in intervention alleged constitutional deprivations in the operation of the jail, including the failure to protect the inmates from harm, insufficient staffing and classification, overcrowding, poor sanitation, failure to supply personal hygiene items, inadequate visitation policies, inadequate recreation and inadequate medical care and diet. In March 1975, the Court granted the motion to intervene. As intervenor, the United States sought to expand the suit to include as parties all inmates in all county and municipal jails in the state and all officials--state and local--responsible in their official capacities for the operation of these jails. The Court found this attempt overbroad, and subsequently dismissed all defendants that lacked a connection with the Houston County Jail. The state defendants stayed in, however, since the U.S. alleged they had some responsibility for conditions at that particular jail. (The U.S. then litigated the conditions in Alabama's largest jail, in Jefferson County, in a different case, Thomas v. Gloor.)

In July 1976, the Court certified a class of plaintiffs consisting of all present and future inmates of the Houston County Jail. Private counsel was appointed to represent the plaintiffs.

On the morning the case was scheduled to go to trial, February 21, 1977, the plaintiffs, the U.S., and the county defendants submitted a partial consent decree to the Court. The state defendants refused to stipulate to the provisions of the decree, so a trial proceeded.

On February 28, 1978, Judge Johnson found for the plaintiffs/U.S., holding: that it was the constitutional duty of the appropriate state officials to supervise agents operating the jail, to stay informed as to the conduct of those agents through regular and thorough inspections, and to enforce established standards and correct the conduct of the agents if necessary. The Court found that the failure of state officials to perform their constitutional duty to correct conditions and to supervise local officials concerning constitutional violations at the jail, including overcrowing, poor sanitation, inadequate diet medical care, justified injunctive relief. The Court also granted attorneys fees, half of which were to be assessed against the defendants who stipulated to the decree and the other half to the defendants represented at trial. The Court required that plaintiffs' counsel monitor compliance with its order. Adams v. Mathis, 458 F.Supp.302 (M.D.Ala. 1978).

On March 17, 1980, the State Fire Marshall, one of the defendants in the lower court trial, appealed the decision. The United States Court of Appeals for the Fifth Circuit affirmed the decision (per curiam). Adams v. Mathis, 614 F.2d 42 (5th Cir. 1980).

On April 14, 1983, plaintiffs' lawyer filed a motion for award of attorney's fees, requesting payment for about 100 hours spent on this case in monitoring compliance. The district court sharply discounted the fees allowed. Plaintiffs appealed, and in an order dated February 4, 1985, the 11th Circuit vacated and remanded for entry of an appropriate, undiscounted, fee. Adams v. Mathis, 752 F.2d 553 (11th Cir. 1985). (In 1981, the 5th Circuit had split and Alabama had been placed into the new 11th Circuit.)

On July 2, 1997 the defendants field a motion to terminate the Partial Consent Decree pursuant to the Prison Litigation Reform Act and on October 1, 1997 that motion was granted. The case therefore ended.