In re Jackson Lockdown/MCO Cases

On May 22, 1981, prisoners at the State Prison of Southern Michigan (SPSM) rioted in response to an allegedly illegal lockdown of the prison imposed by prison guards who were members of the Michigan Corrections Organization labor union (MCO) (defendant). Prison authorities secured control of SPSM on May 23, but the prisoners rioted again on May 26. To regain control of the prison, prison guards prevented prisoners from accessing the prison yard, law library, cafeteria, hygiene facilities, religious services, and rehabilitation programs. Beginning in June 1981, individual SPSM prisoners (plaintiffs) brought lawsuits against MCO and various corrections officials, alleging that MCO members had instigated the riots and violated the prisoners’ constitutional rights. The prisoners sought declaratory relief and money damages. The prisoners’ cases were ultimately consolidated for pretrial purposes in federal district court in Michigan. Separately, in a federal class action (the Walker action), a class of prisoners including the plaintiffs of the consolidated action against MCO challenged the constitutionality of the conditions of their confinement at three Michigan prisons, including conditions imposed after the May 1981 riots. The prisoners in the Walker action sought only declaratory and injunctive relief; the Walker complaint stated that class members would individually bring separate damages actions. The Walker court thus limited class certification to the prisoners’ claims for declaratory and prospective relief. Following a trial, the court in the Walker action found that some of the prison conditions were unconstitutional. While the Walker judgment was on appeal, MCO moved for summary judgment in the consolidated actions, arguing that the judgment in Walker barred the prisoners’ actions because the Walker class had failed to assert damages claims. MCO asserted that allowing the prisoners to assert separate claims for damages went against the principle that a single cause of action should not be split into multiple litigations.