Case: Groseclose v. Dutton

On June 6, 1984, a petition for writ of habeas corpus was filed by third parties on behalf of Ronald Harries who was confined to Unit IV of the Tennessee State Penitentiary. William Groseclose and others brought the case on Harries' behalf after he refused to appeal his death sentence due to the adverse conditions of his confinement. An order staying Harries' execution was granted. Groseclose v. Dutton, 589 F.Supp. 362 (M.D. Tenn. 1984). A subsequent order denied defendants motion to dismiss and continued the stay. Groseclose v. Dutton, 594 F.Supp. 949 (M.D. Tenn. 1984).

Plaintiffs also alleged civil rights violations regarding the conditions of Unit IV. Plaintiffs were represented by private council. On November 13, 1984, a class was certified composed of those persons on death row and future inmates who would be confined in Unit IV under sentence of death. The class also included the American Civil Liberties Union of Tennessee. The court bifurcated the habeas corpus claim and the civil rights claim concerning the prison conditions. After an evidentiary hearing, the district court (Judge John T. Nixon) declared the prison conditions on Unit IV (death row) to be unconstitutional and ordered the defendant to submit a good faith remedial plan to correct the conditions. Groseclose v. Dutton, 609 F.Supp. 1432 (M.D. Tenn. 1985). Among the court's concerns with the prison were the small size of the cells, insect infestation, absence of fire drills, insufficient human interaction, and the lack of opportunity for religious services.

An appeal by the defendant was dismissed on April 14, 1986 by the Court of Appeals because the district court's order was not an appealable final judgment. Groseclose v. Dutton, 788 F.2d 356 (6th Cir. 1986). The case was re-heard by the Court of Appeals en banc on November 3, 1987 after a master plan was accepted by the district court and a special master was appointed to monitor its implementation. The court (Judge David A. Nelson) vacated the judgment of the district court. Groseclose v. Dutton, 829 F.2d 581 (6th Cir. 1987). The court concluded that the case should have been consolidated with a pending class action lawsuit involving the constitutionality of conditions throughout the Tennessee prison system. (Grubbs v. Bradley, 552 F.Supp.1052 (M.D. Tenn. 1982)). (PC-TN-007) Second, it concluded that the district court had applied an incorrect legal standard in determining whether prison conditions violated the Eight Amendment. On May 11, 1988, the case was remanded to the district court for further proceedings after a settlement was reached by the parties. Groseclose v. Dutton, 848 F.2d 190 (6th Cir. 1988). The order approving the settlement provides no details or specifics of the settlement.

Subsequent litigation concerning Harries' mental capacity and psychiatric treatment continued for several years. On October 22, 1999, Groseclose was deleted as a party to the action and his name was deleted from all future pleadings. On August 23, 2002, Judge John T. Nixon vacated Harries' death sentence and remanded the case to the State of Tennessee for further proceedings.