Brown, Governor of California v Plata

Abstract

This case note examines the controversial decision of the US Supreme Court which, by a majority of 5:4 held that California should reduce its prison population as overcrowding levels gave rise to cruel and unusual punishment. The implications of the case for the interpretation of when prisoners' rights under the Eighth Amendment are breached, the separation of powers are discussed; the possible impact on prison rates in the USA is also examined.

California Prison Realignment

“…Due to this increase in incarceration, the state budget for the CDCR increased from $3.5 billion in 1998 to $10.3 billion in 2009 (CDCR, 2011). California's prison expenditures have risen to ten percent of the State's budget in 2011, when they were only four percent in the mid 1980s (Rogan, 2012). More specifically, the average cost per inmate in the state of California increased to $48,536 per year by 2009 (Harvard Law Review, 2010).…”

“…inmates (Rogan, 2012). Since 1970, California has seen 750% rise in incarceration levels, especially during the "war on drugs" campaign during the 1990s (Harvard Law Review, 2010, p. 753).…”

“…With no end in sight to the rapidly growing number of inmates in California's state prisons, the CDCR was challenged to manage the growing population. New prison construction was a short-term solution as the number of prisoners continued to rise and budgets continued to fall, limiting construction funding (Rogan, 2012).…”

“…The safe operation of a prison is impossible with severe overcrowding (Spector, 2010). In a similar case filed approximately a decade later in Plata v. Brown (2001), the court ruled that the CDCR failed to provide adequate medical services and consequently violated the Eight Amendment (Rogan, 2012). The outcomes of these cases led to a court-ordered reduction in overcrowding, and because of the poor level and standards of prisoner healthcare, the California prison system was forced to change prisoners' housing.…”

“…This case followed the precedent set in the Coleman case. Plata v. Brown argued that the CDCR violated not only the Eighth Amendment, but also the Americans with Disabilities Act of 1990 and the Rehabilitation Act of 1973 (Rogan, 2012). Judge Henderson, who was hearing the Plata case in 2005, put the entire CDCR healthcare system on receivership.…”