Case: Brown v. Hutto

3:81-00853 | U.S. District Court for the Eastern District of Virginia

Filed Date: Aug. 1, 1981

Closed Date: 1997

Clearinghouse coding complete

Case Summary

On August 1, 1981, prisoners confined at the Mecklenburg Correctional Center (MCC) in Boydton, Virginia, filed a class action lawsuit under 42 U.S.C. §1983 against the Virginia Department of Corrections in the U.S. District Court for the Eastern District of Virginia. The plaintiffs asked the Court for declaratory and injunctive relief, alleging that the totality of conditions at the MCC fell "beneath the standards of human decency" and inflicted needless suffering in violation of their constit…

On August 1, 1981, prisoners confined at the Mecklenburg Correctional Center (MCC) in Boydton, Virginia, filed a class action lawsuit under 42 U.S.C. §1983 against the Virginia Department of Corrections in the U.S. District Court for the Eastern District of Virginia. The plaintiffs asked the Court for declaratory and injunctive relief, alleging that the totality of conditions at the MCC fell "beneath the standards of human decency" and inflicted needless suffering in violation of their constitutional rights. Specifically, they complained of staff that were inadequately trained and unsupervised, lack of programming and activities, inadequate medical and psychiatric services, and a continuing atmosphere of violence, which they claimed led to inmates suffering injuries in physical confrontations with guards and use of excessive force.

On February 23, 1982, the District Court (Judge Robert Reynold Merhige, Jr.) found it unnecessary to resolve the plaintiffs' motions for a protective order and a preliminary injunction, noting that the parties claimed to have resolved those issues by mutual consent.

On April 8, 1983, the parties entered into a settlement agreement, under which the defendants agreed to form an Institutional Classification Committee for the purpose of classifying inmates when they entered the prison. The defendants also agreed to convert cell lights to a system that was internally controlled, to attach steel desks and stools inside the cells, to install window knobs on cell windows, to establish a written policy delineating when the toilets in the isolation units could be turned off (e.g. as a result of an inmate's deliberate flooding of the cell) and providing that no inmate shall be required to consume his meal in a cell with an unflushed toilet, to have psychological staff monitor inmates who were being controlled by physical restraints, to use such restraints only after consultation with a psychologist or doctor except in emergencies. The defendants also agreed not to establish a segregation section in death row, and to subject death row inmates only to ordinary disciplinary and security procedures. The settlement agreement also covered use of the telephones, visitation, outdoor recreation, food service, use of chemical restraints, disciplinary reporting procedures, grievance procedures, staff training and rotation, background checks for staff members, medical and psychiatric care, law library use, mail, newspapers, religious programming, search policies, educational opportunities, use of metal detectors, and access to a general reading library.

On April 22, 1983, the District Court found the settlement agreement to be a fair resolution of all issues between the parties except attorneys' fees, and therefore adopted the agreement as the order of the Court. The order became final on August 2, 1983.

On March 29, 1985, the parties jointly moved the court for an order modifying the consent decree, and on April 5, 1985, the parties entered into a new consent decree. Under the new decree, most of the resolutions in the original decree remained untouched, but the parties made some minor changes to the classification process. The Court adopted the new decree.

On April 7, 1997, the consent decree was vacated without opinion by the District Court pursuant to 18 U.S.C. § 3626(b)(2), and the case was closed.

Summary Authors

Kristen Sagar (10/15/2007)

Related Cases

Thorpe v. Virginia Department of Corrections, Eastern District of Virginia (2019)

People


Judge(s)

Merhige, Robert Reynold Jr. (Virginia)

Attorneys(s) for Plaintiff

Alexander, Elizabeth R. (District of Columbia)

Bronstein, Alvin J. (District of Columbia)

Hickey, J. Patrick (District of Columbia)

Hirschkop, Phillip J. (Virginia)

Litt, Barrett S. (California)

Tisdale, Stuart W. Jr. (District of Columbia)

Vaid, Urvashi (District of Columbia)

Zerkin, Gerald T. (Virginia)

Attorneys(s) for Defendant

Gorman, Richard F. III (Virginia)

Judge(s)

Merhige, Robert Reynold Jr. (Virginia)

Attorneys(s) for Plaintiff

Alexander, Elizabeth R. (District of Columbia)

Bronstein, Alvin J. (District of Columbia)

Hickey, J. Patrick (District of Columbia)

Hirschkop, Phillip J. (Virginia)

Litt, Barrett S. (California)

Tisdale, Stuart W. Jr. (District of Columbia)

Vaid, Urvashi (District of Columbia)

Zerkin, Gerald T. (Virginia)

Attorneys(s) for Defendant

Gorman, Richard F. III (Virginia)

Miller, Burnett III (Virginia)

Documents in the Clearinghouse

Document

Complaint

Aug. 1, 1981 Complaint

Proposed Order

Feb. 23, 1982 Order/Opinion

Amended and Supplemental Complaint

Brown v. Procunier

July 29, 1982 Complaint

Order

U. S. Court of Appeals for the Fourth Circuit

692 F.2d 751

Oct. 25, 1982 Order/Opinion

Settlement Agreement

Brown v. Procunier

April 8, 1983 Settlement Agreement

Order

Brown v. Procunier

April 22, 1983 Order/Opinion

Order

Brown v. Landon

Aug. 2, 1983 Order/Opinion

Motion for Modification of Consent Decree

Brown v. Procunier

March 29, 1985 Pleading / Motion / Brief

Plaintiff's Memorandum in Support of Entry of Modified Consent Decree

Brown v. Sielaff

March 29, 1985 Pleading / Motion / Brief

Order

Brown v. Procunier

April 5, 1985 Order/Opinion

Resources

Title Description External URL

Jail Strip-Search Cases: Patterns and Participants

Margo Schlanger

This article looks at jail strip-search litigation and its participants, to analyze its internal dynamics. Among the interesting features of these cases is that many different kinds of lawyers work … April 1, 2008 https://scholarship.law.duke.edu/...

The Caged Canary

Elizabeth Alexander

The United States has experienced an explosion in the number of people in prison, an explosion that cannot be attributed to changes in the crime rate, but rather reflects changes in public policy, pa… Dec. 1, 2008 http://scholarship.law.wm.edu/...

Docket

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

Docket sheet not available via the Clearinghouse.

State / Territory: Virginia

Case Type(s):

Prison Conditions

Special Collection(s):

Strip Search Cases

Key Dates

Filing Date: Aug. 1, 1981

Closing Date: 1997

Case Ongoing: No

Plaintiffs

Plaintiff Description:

prisoners confined at the Mecklenburg Correctional Center (MCC) in Boydton, Virginia

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

ACLU National (all projects)

ACLU National Prison Project

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Virginia Department of Corrections (Boydton, Mecklenburg), State

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Constitutional Clause(s):

Due Process

Freedom of speech/association

Cruel and Unusual Punishment

Availably Documents:

Complaint (any)

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1983 - 1997

Content of Injunction:

Preliminary relief request withdrawn/mooted

Issues

General:

Access to lawyers or judicial system

Assault/abuse by staff

Bathing and hygiene

Classification / placement

Disciplinary procedures

Education

Food service / nutrition / hydration

Grievance Procedures

Law library access

Library (non-law) access

Loss or damage to property

Mail

Personal injury

Phone

Recreation / Exercise

Religious programs / policies

Restraints : chemical

Restraints : physical

Search policies

Staff (number, training, qualifications, wages)

Strip search policy

Suicide prevention

Totality of conditions

Visiting

Medical/Mental Health:

Medical care, general

Mental health care, general

Type of Facility:

Government-run