Case: Cagle v. Hutto

3:79-00515 | U.S. District Court for the Eastern District of Virginia

Filed Date: May 30, 1979

Closed Date: 2000

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Case Summary

Sometime in 1979, an inmate at the Powhatan Correctional Center (PCC) filed a lawsuit under 42 U.S.C. § 1983 against the Virginia Department of Corrections in United States District Court in the Eastern District of Virginia alleging Eighth Amendment violations. Specifically, the inmate alleged that the totality of the conditions at PCC amounted to cruel and unusual punishment. Similar inmate cases were consolidated with the Cagle case on January 15, 1980 and on February 19, 1980. Plaintiffs,…

Sometime in 1979, an inmate at the Powhatan Correctional Center (PCC) filed a lawsuit under 42 U.S.C. § 1983 against the Virginia Department of Corrections in United States District Court in the Eastern District of Virginia alleging Eighth Amendment violations. Specifically, the inmate alleged that the totality of the conditions at PCC amounted to cruel and unusual punishment. Similar inmate cases were consolidated with the Cagle case on January 15, 1980 and on February 19, 1980. Plaintiffs, represented by private counsel, sought compensatory and declaratory relief.

On June 18, 1980, the plaintiffs filed an amended complaint and moved for class certification. The class was certified on October 7, 1980 to include present and future inmates at the Powhatan Correctional Center. During a hearing on the inmates' motion for a preliminary injunction, the District Court (Judge David Dortch Warriner) found that there was a "pervasive risk of harm" to prisoners at PCC. Negotiations followed, and the parties entered into a Consent Decree which was approved by the District Court on February 12, 1981. The Decree provided various forms of injunctive relief and contemplated continued supervision by the District Court through the filing of periodic compliance reports.

On April 26, 1996, the President signed the Prison Litigation Reform Act, which stated that prospective relief in prison conditions cases "shall extend no further than necessary to correct the violation of the Federal right of a particular plaintiff or plaintiffs." 18 U.S.C. § 3626(a)(1).

On March 14, 1997, the defendants filed a motion to terminate Consent Decree. On May 14, 1998, the District Court (Judge James R. Spencer) granted defendants' motion and vacated the Consent Decree. The class of inmates appealed.

On May 28, 1999, the United States Court of Appeals for the Fourth Circuit (Judge William Walter Wilkins) affirmed, holding that: (1) the PLRA was constitutional; (2) the PLRA did not provide an avenue for district courts to make, post hoc and nunc pro tunc, the findings required by the Act in order to avoid termination of a consent decree; (3) state did not waive the right to obtain termination of the decree; (4) the PLRA did not mandate an evidentiary hearing in all cases; and (5) there was no abuse of discretion in refusing to conduct an evidentiary hearing in the instant case.

On June 26, 2000, the Supreme Court denied the plaintiff's petition for writ of certiorari.

Summary Authors

Emilee Baker (11/2/2006)

People


Judge(s)

Hamilton, Clyde H. (South Carolina)

Wilkins, William Walter (South Carolina)

Attorney for Plaintiff

Starke, Karen Lee (Virginia)

Attorney for Defendant

Earley, Mark Lawrence (Virginia)

Muse, William W. (Virginia)

Judge(s)

Hamilton, Clyde H. (South Carolina)

Wilkins, William Walter (South Carolina)

Wilkinson, James Harvie III (Virginia)

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Documents in the Clearinghouse

Document

98-06912

Brief of Appellees

U.S. Court of Appeals for the Fourth Circuit

Oct. 15, 1998

Oct. 15, 1998

Pleading / Motion / Brief

98-06912

Opinion

U.S. Court of Appeals for the Fourth Circuit

May 28, 1999

May 28, 1999

Order/Opinion

177 F.3d 177

99-06865

Memorandum Decision

Supreme Court of the United States

June 26, 2000

June 26, 2000

Order/Opinion

530 U.S. 530

Docket

Last updated Feb. 15, 2024, 3:16 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Virginia

Case Type(s):

Prison Conditions

Key Dates

Filing Date: May 30, 1979

Closing Date: 2000

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Present and future inmates of the Powhatan Correctional Center in Virginia

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Virginia Department of Corrections, State

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

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1981 - 1998

Content of Injunction:

Preliminary relief request withdrawn/mooted

Issues

General:

Bathing and hygiene

Classification / placement

Education

Food service / nutrition / hydration

Recreation / Exercise

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Totality of conditions

Jails, Prisons, Detention Centers, and Other Institutions:

Crowding / caseload

Assault/abuse by non-staff (facilities)

Type of Facility:

Government-run