Case: Nadeau v. Helgemoe

On March 17, 1976, New Hampshire state prisoners who were held in protective custody ("PC") at their own request filed suit under 42 U.S.C. Section 1983, in the United States District Court for the District of New Hampshire against the New Hampshire State Prison alleging unconstitutional conditions of confinement on First, Sixth, Eighth, and Fourteenth Amendment grounds. The PC prisoners alleged that the prison placed stricter restrictions on the range of activities and work opportunities compared available to them as compared to the general population; that PC inmates who were unable to work did not receive the "idle pay" that non-working, general population prisoners received; that PC prisoners were put in danger of verbal and physical attack when they were escorted through the general population to meet with visitors or receive medical or educational services; that they had restricted library access of less than an hour per week and less outdoor recreation time than general population prisoners; that they did not get second servings of lunch and supper, unlike the general population prisoners, and that those meals were served to the PC prisoners an hour earlier than to general population prisoners and were served to PC prisoners in their cells, rather than communally; and that religious services were not held in the building in which PC prisoners were housed.

The United States District Court for the District of New Hampshire (Judge Hugh Henry Bownes) applied Eighth and Fourteenth Amendment tests that required all punishments to have a legitimate penological purpose and found that fiscal limitations were not sufficient state interests to justify distinctions between PC and general population prisoners. Nadeau v. Helgemoe, 423 F.Supp. 1250 (N.H. 1976). Applying these tests, the court found that a few of the grievances, such as those concerning security, and religious and medical services, were not proper grounds for relief, but found overwhelmingly for plaintiffs on the other grievances, such as the amount of time PC prisoner were allowed to spend out of their cells, the time and location of meals, and the limited availability of certain activities and work opportunities to PC prisoners. Nadeau v. Helgemoe, 423 F.Supp. 1250 (N.H. 1976).

The United States Court of Appeals for the First Circuit (Judge Frank Morey Coffin) affirmed the portion of the District Court opinion that required increased access to the library for PC prisoners, but vacated and remanded the remainder of the issues for consideration under the proper Eighth and Fourteenth Amendment standards. Nadeau v. Helgemoe, 561 F.2d 411, 415 (1st Cir. 1977). The First Circuit Court of Appeals found that the proper test under the Eighth Amendment was whether the conditions at the prison were "indisputably barbaric and indecent," and that the test called for a high degree of deference for legislative and administrative judgments. Further, the court found the Fourteenth Amendment did not require conditions of PC to equal those of the general population in all respects; rather the standard was whether any distinctions made between the groups were rational rather than arbitrary and capricious.

Subsequent litigation involved attorney's fees. Ultimately, the U.S. Court of Appeals for the First Circuit (Judge Coffin) found that plaintiffs could be considered "prevailing parties," and be awarded attorney's fees. Nadeu v. Helgemoe, 581 F.2d 275 (1st Cir. 1978). The case was remanded to the U.S. District Court for the District of New Hampshire for determination of appropriate fees.

Because this case predates pacer, we do not have any further information. The case is presumably now closed.