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Hutto v. Finney

United States Supreme Court
437 US. 678 (1978)


Facts

In 1969, Arkansas inmates (plaintiffs) sued, alleging that the conditions of the jail constituted violations of the Eighth and Fourteenth Amendments. The district court described the conditions endured by these inmates as a dark and evil world completely alien to the free world. The evidence overwhelmingly supported this conclusion. The jail was overcrowded because it housed 1,000 inmates. In addition to many other issues, the jail utilized the practice of punitive isolation, which resulted in multiple inmates being placed in windowless 8’ x 10’ cells. The cells contained no furniture other than a source of water and a toilet that would only flush from outside of the cell. The prisoners in isolation would receive fewer than 1,000 calories per day. The district court directed the Arkansas Department of Corrections to make a substantial start on improving conditions and to file reports on its progress. After a second hearing on the jail conditions, the district court concluded that the conditions remained unconstitutional, and issued guidelines to address the four most serious areas that needed to be improved. These areas were improving conditions in the isolation cells, increasing inmate safety, eliminating the barracks sleeping arrangements, and ending the trusty system. The court held additional hearings through the next few years, and discovered, during a hearing in 1976, that conditions had substantially deteriorated. The inmate population increased to 1,500 and the isolation cells were particularly disturbing. The cells had been vandalized, prisoners were being kept in them for months at a time, violence among the inmates was rampant, and the guards were forced to use nightsticks and mace to control the inmates. The trial court entered an injunction requiring that the 1,000 calorie diet be discontinued, the number of inmates in one cell be limited, a bunk be placed in each cell, and that an isolation sentence could not exceed 30 days at time.

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Holding and Reasoning (Stevens, J.)

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Dissent (Rehnquist, J)

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