Women Prisoners of the District of Columbia Department of Corrections v. District of Columbia

The District of Columbia (DC) (defendant) segregated its prison system by sex. There was a widespread practice of prison guards exploiting the female prisoners (plaintiffs) for sex, and all the women’s prisons lacked consistent physical or mental healthcare. DC also offered different programming at the men’s prisons versus the women’s. The men’s minimum-security prison offered college classes and a law library to its 936 prisoners, but the women’s minimum-security prison offered no educational options and only limited outside-library access for its 167 prisoners. DC also provided more work, recreational, and religious programs at the men’s minimum-security prison than at the women’s. DC’s three men’s medium-security prisons each housed between 1,000 and 1,700 prisoners, many serving extended sentences. The women’s medium-security prison housed 271 prisoners, most serving four years or less. DC’s female prisoners brought a class action in federal district court, seeking multiple reforms. The parties settled some claims and went to trial on the others. Evidence was presented about differences between the opportunities DC offered to male and female prisoners, but not about how much it allocated for each sex. Among other rulings, the district court held (1) DC’s male and female prisoners were similarly situated because they had similar custody levels, sentence structures, and incarceration purposes; (2) female prisoners had significantly less access to educational, work, recreational, and religious programs than male prisoners; and (3) providing vastly different programming access based on sex violated the Title IX federal statute and the Fourteenth Amendment’s Equal Protection Clause. The court ordered DC to upgrade the female prisoners’ access to these programs. DC accepted the ruling regarding the educational opportunities but appealed the ruling that it needed to increase the female prisoners’ access to work, recreational, and religious programs.