Case: Blake v. Hall

This case was an ultimately successful Eighth Amendment challenge of the conditions at a Massachusetts prison. The housing sections were horrendously filthy and the subterranean protective custody unit, where inhabitants had no out-of-cell time, was likened to a medieval dungeon.

In 1978, six incarcerated persons filed a class action suit in the U.S. District Court for the District of Massachusetts. They alleged there were horrid conditions at the then 23-year-old maximum-security Massachusetts Correctional Institution, Walpole. Under 42 U.S.C. § 1983, defendants’ failure to address these conditions violated the Eighth Amendment’s ban on cruel and unusual punishment. They sought damages alongside declaratory and injunctive relief. Defendants included various state officials, including the Commissioner of Corrections, the Superintendent of M.C.I. Walpole, the Commissioner of Public Health, and the Secretary of Human Services. Judge John J. McNaught was assigned.

Plaintiff’s Eighth Amendment allegations were twofold.

First, they challenged the horrendous conditions at M.C.I. Walpole generally. The worst were found in “Block 10,” an area which housed individuals whom the administration felt were the most disruptive. A non-exclusive list of the allegations for Block 10 included:

• Walls caked in dirt, grime, and human excrement.
• Garbage and debris lining the floors.
• Roof leaks which left the facility damp, moldy, and grimy.
• Broken windows without screens.
• Poor ventilation, leading to excessive heat on upper floors, and chilling temperatures on lower floors.
• Filthy and/or broken toilets and showers.
• Cockroach and rat infestations.

Second, plaintiffs challenged the prison’s “New Man’s Section.” This section housed individuals who requested separation from the general population. In a First Circuit opinion discussed later, the area was likened to a “medieval dungeon." It was located entirely underground beneath the prison’s infirmary. There was no natural light and little to no ventilation. On top of that, individuals housed in this section did not have any opportunity for outdoor recreation or even out-of-cell recreation.

Defendants’ main argument was that the conditions were due to openly defiant incarcerated individuals. Officials were just doing their best to cope. Regarding the “New Man’s Section,” they argued that its inhabitants were there voluntarily after requesting removal from the general population. Additionally, defendants claimed they intended to close the section.

On May 2, 1979, the court responded to the defendants’ motion to dismiss both the Commissioner of Public Health and the Secretary of Human Services (469 F.Supp. 1025). The court denied the motion for the former and granted it for the latter. The main difference between the two was that only the Commissioner was explicitly delegated the responsibility of overseeing health and sanitation laws. This included a requirement for inspecting all correctional facilities. 

The plaintiffs’ damages claims were tried by a jury with a verdict for the defendants. Unfortunately, there was no publicly available information on the specifics of this trial.

A year after the trial, the court denied plaintiffs' declaratory and injunctive claims. While the full opinion isn’t available, the First Circuit subsequent opinion quoted the district court that while the conditions “leave a great deal to be desired” they were not sufficiently shocking or barbarous to be unconstitutional. Additionally, the district court accepted defendants’ argument that the “problems of which complaints were made were created by the plaintiff class, in large measure.” In addition, the court had relied on defendants’ representations that they planned to close the “New Man’s Section.” Plaintiffs appealed to the First Circuit.

On December 18, 1981, the First Circuit opinion upheld the District Court’s decision regarding damages while overturning its decision on declaratory, injunctive relief, and the “New Man’s Section.” (668 F.2d 52). In short, the conditions at the prison violated the Eighth Amendment. 

Regarding the damages claims, they may be blocked by the alleged conduct of plaintiffs and other incarcerated individuals. However, regarding the injunctive and declaratory claims, this conduct was not a proper factor to consider for cruel and unusual punishment. The court saw “no reason why well-behaved inmates should have to suffer cruel and unusual punishment because of the actions of some disruptive ones[.]” Further, defendants were charged by law to run the facility and “dealing with violent and disruptive men without violating the cruel and unusual punishment proscription of the eighth amendment is their job.” There was also no available precedent for denying equitable relief due to prison conditions created in part by incarcerated individuals.

Regarding the “New Man’s Section,” the First Circuit stated it was “[d]ifficult for us to understand why confining men in a dungeon . . . does not offend society’s evolving sense of decency[.]” Further, defendants’ claim that those housed in the “New Man’s Section” did so voluntarily “overlooked the realities of prison life at Walpole[.]” For many housed there, the choice was between facing the horrid conditions or facing assault, perhaps even death. Ultimately, the court remanded the case for plaintiffs to prove their allegations that defendants no longer intended to close the “New Man’s Section.” If shown, the district court should then determine the section would constitute cruel and unusual punishment. 

Defendants attempted to appeal to the U.S. Supreme Court, but certiorari was denied on May 17, 1982 (456 U.S. 983).

On June 2, 1983, the District Court permanently enjoined M.C.I. Walpole from using the “New Man’s Section” for housing (563 F. Supp. 836). They determined that the section’s conditions violated the Eighth Amendment. In fact, the court stated it would have issued the injunction years earlier had defendants not represented that they intended to close the section. The prison had started allowing people housed in the section very limited out-of-cell time. However, the conditions, ranging from lacking ventilation and faulty plumbing, still fell below the constitutional standard. 

No further actions have occurred in this case.

In April 2022, Massachusetts announced that M.C.I. Walpole (now known as M.C.I. Cedar) was closing. They cited both decreased prison housing needs and the aging facility’s high maintenance costs.