Madrid v. Gomez

California’s Pelican Bay State Prison had a secure housing unit (SHU) that, by design, imposed harsh conditions on prisoners. Prisoners were sent to SHU if they committed serious disciplinary infractions while in prison, exhibited a tendency to commit assaults, or were affiliated with prison gangs. At SHU, prisoners were allowed almost no contact with other humans, other than possibly a cellmate. However, cellmate relationships were often violent and provided little positive social interaction. SHU prisoners spent 22.5 hours each day in their cells. These cells were intentionally low on stimulation, with white walls, no windows, and limited views of the white walls outside each cell. SHU prisoners had limited interaction with staff. For example, when a prisoner was allowed to visit the empty room that functioned as an exercise area, the doors between the prisoner and that area would be opened and closed from a remote area using electronic controls. In addition, SHU prisoners were not allowed to work, they were allowed only very limited entertainment options, and any visitors were kept physically separated by thick plastic. A class of Pelican Bay prisoners (the prisoners) (plaintiffs) sued James Gomez (defendant), the director of California’s Department of Corrections in federal district court. Among other claims, the prisoners alleged that SHU’s conditions violated their rights under the Eighth Amendment. The prisoners claimed that SHU’s extreme social isolation and reduced environmental stimulation inflicted psychological trauma that deprived some prisoners of their basic human need for sanity. The court held a bench trial. Evidence showed that SHU’s conditions caused some prisoners to experience only minor psychological trauma but caused other prisoners to experience severe psychological trauma, such as hallucinations, psychotic breaks, and suicidal tendencies. The two groups most likely to experience severe psychological trauma from SHU’s conditions were prisoners who either (1) currently had a mental illness or (2) had another condition that made them particularly sensitive to SHU’s stimulation deprivation, such as a prior mental illness, brain damage, cognitive-development issues, impulse-ridden personalities, or a borderline personality disorder. Based on the evidence, the court made findings of fact and conclusions of law.