California First Amendment Coalition vs. Woodford

William Bonin was on death row at San Quentin State Prison, located in San Quentin, California. The prison adopted a policy known as Procedure 770. The procedure imposed public-viewing restrictions on prisoner executions by lethal injection and, specifically, prohibited the public from observing an execution until after all execution-team members exited the chamber where the condemned would be put to death. A curtain obstructed the public’s view of the chamber. By the time the curtain to the chamber was opened, all predeath preparations had been completed, and the prisoner could only be observed lying motionless on the gurney. With the exception of the procedure, California prisons had historically allowed for unfettered public access to prisoner executions. Following Bonin’s execution, the California First Amendment Coalition and the Society of Professional Journalists (collectively, the journalists) (plaintiffs) filed suit in federal court against Jeanne Woodford (defendant), the acting prison warden. As part of the suit, the journalists also requested a preliminary injunction requiring Woodford to permit the journalists to observe execution proceedings from the time that the intravenous tubes were inserted into the prisoner until after the prisoner’s death. The journalists alleged that the First Amendment to the United States Constitution provided members of the public and the media a qualified right of access to government proceedings. The journalists also asserted that the same right that the public and the media had to access criminal proceedings in court must be extended to the execution of the convicted in prison to determine whether the process was humane. The district court granted the journalists’ request for a preliminary injunction, and Woodford appealed.