Brown v. Plata Case Brief Summary | Law Case Explained

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Brown v. Plata | 563 U.S. 493 (2011)

Prior to 1995, many federal courts remediated unconstitutional prison conditions by issuing structural injunctions, which order government institutions to comply with constitutional requirements. Concerned about the scope of such injunctions, Congress adopted the Prison Litigation Reform Act of 1995, or the PLRA. In Brown versus Plata, we explore the PLRA’s restrictions on structural injunctions that combat prison overcrowding.

For more than eleven years, California’s prison system operated at almost 200 percent capacity. During that period, two federal class actions alleged that state prison conditions constituted cruel and unusual punishment, violating the Eighth Amendment. In Coleman versus Brown, prisoners with mental illnesses alleged that a shortage of space and staff resulted in extended delays for mental-health care. The district court appointed a special master to oversee remediation, but twelve years later, the special master reported that conditions were worsening due to overcrowding.

In Plata versus Brown, prisoners with serious medical conditions alleged that a lack of staff and equipment resulted in inadequate medical care. The district court issued a structural injunction and eventually appointed a receiver to oversee remediation. But the receiver reported that rampant overcrowding precluded improvement.

Because overcrowding hindered remediation in Coleman and Plata, the plaintiffs in each case moved to convene a three-judge district court under the PLRA that could order a reduction of the prison population. The requests were granted and the cases consolidated.

The three-judge court ordered California to bring the prison population to within 137.5 percent of the prison system’s capacity. Although the order didn’t stipulate how the state must meet that goal, the order effectively mandated the release of up to forty-six thousand prisoners unless California built additional facilities or arranged out-of-state transfers. California appealed to the United States Supreme Court.

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