Case: Strachan v. Ashe

1:79-02001 | U.S. District Court for the District of Massachusetts

Filed Date: Oct. 2, 1979

Closed Date: 1982

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Case Summary

This was a § 1983 case filed by an incarcerated individual challenging the conditions of confinement in a hospital isolation cell in a county house of corrections. The plaintiff was incarcerated at the Hampden County House of Correction in Massachusetts. He was confined to a hospital isolation cell when he filed this action on October 2, 1979, and sought declaratory and injunctive relief, along with damages, against five defendants named individually and in their official capacities. The plain…

This was a § 1983 case filed by an incarcerated individual challenging the conditions of confinement in a hospital isolation cell in a county house of corrections. The plaintiff was incarcerated at the Hampden County House of Correction in Massachusetts. He was confined to a hospital isolation cell when he filed this action on October 2, 1979, and sought declaratory and injunctive relief, along with damages, against five defendants named individually and in their official capacities. The plaintiff was represented by the Prisoners Legal Assistance Clinic at the Western New England College of Law.

In his complaint the plaintiff made allegations regarding the conditions of his isolation cell, including inadequate sanitation, heating, food temperature, bedding, and recreation. After

Discovery, the plaintiff was granted leave to file an amended complaint, which expanded the claims of plaintiff to claims on behalf of a class of persons similarly situated. In August 1980, the plaintiff moved for class certification and the matter was referred to a magistrate. The magistrate recommended denial of the motion, but the United States District Court for the District of Massachusetts (Judge Frank Freedman) rejected the magistrate's recommendation and ordered that a hearing be scheduled. The plaintiff also moved for partial summary judgment on his claim for damages, and a hearing was held on those motions on June 4, 1982. After the hearing, Judge Freedman told the parties he would leave the record open for one week to permit the parties to file additional evidentiary materials.

In a reported decision dated October 13, 1982, the district court refused to certify the class. Strachan v. Ashe, 548 F.Supp. 1193 (D. Mass. 1982).The court held that the conditions of confinement in the hospital isolation cell amounted to cruel and unusual punishment of the individual plaintiff and that the jail officials could be held liable for monetary damages. The court thus granted plaintiff's motion for partial summary judgment, and stated that the case could proceed to trial on the issue of damages.

There is no docket available for this case, and there is no indication of whether damages were paid or if the case was ever resolved and closed.

Summary Authors

Theresa Spaulding (6/16/2005)

People


Judge(s)

Freedman, Frank Harlan (Massachusetts)

Attorney for Plaintiff

Thompson, John M. (Massachusetts)

Attorney for Defendant

Basile, Savino J. (Massachusetts)

Keaney, J. David (Massachusetts)

McDonough, Edward J. Jr. (Massachusetts)

Judge(s)

Freedman, Frank Harlan (Massachusetts)

Attorney for Plaintiff

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Documents in the Clearinghouse

Document

1:79-02001

Memorandum

Oct. 13, 1982

Oct. 13, 1982

Order/Opinion

548 F.Supp. 548

Docket

Last updated March 24, 2024, 3:07 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Massachusetts

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Oct. 2, 1979

Closing Date: 1982

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Inmate challenging the conditions of confinement in a hospital isolation cell in a county house of corrections

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

State of Massachusetts (Hampden), County

Defendant Type(s):

Jurisdiction-wide

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Available Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Damages

Source of Relief:

Litigation

Order Duration: 1982 - None

Issues

General:

Conditions of confinement

Disciplinary procedures

Food service / nutrition / hydration

Recreation / Exercise

Sanitation / living conditions

Jails, Prisons, Detention Centers, and Other Institutions:

Disciplinary segregation

Type of Facility:

Government-run