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In re Medley

134 U.S. 160 (1890)

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In re Medley

United States Supreme Court
134 U.S. 160 (1890)

Facts

James Medley (defendant) was convicted of murder and sentenced to death by the State of Colorado. At the time Medley committed the murder, the state’s death-sentence law did not require solitary confinement. However, in between when Medley committed the crime and when he was sentenced, a new state law became effective. Under this new statute, prisoners who had been sentenced to death were required to be kept in solitary confinement until executed. In accordance with this new law, Medley was sentenced to be imprisoned in solitary confinement until his execution date. Medley filed a petition for a writ of habeas corpus with the United States Supreme Court. In this petition, Medley argued that the state’s new solitary-confinement requirement was an increased punishment that could not be applied retroactively to his crime. While considering the petition, the Court took judicial notice of information that (1) prisoners who were subjected to solitary confinement frequently became catatonic, went insane, or committed suicide and (2) prisoners who survived solitary confinement were often too damaged to serve society.

Rule of Law

Issue

Holding and Reasoning (Miller, J.)

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