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Rhodes v. Chapman

452 U.S. 337 (1981)

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Rhodes v. Chapman

United States Supreme Court

452 U.S. 337 (1981)

Facts

Kelly Chapman (plaintiff) was a prisoner at Southern Ohio Correctional Facility (SOCF) who was permanently housed in a 63-square-foot cell with another inmate. Chapman sued SOCF’s administrators (defendants) alleging that SOCF was double celling inmates due to the prison’s overcrowded population. Chapman requested an injunction prohibiting double celling as an unconstitutional practice in violation of the Eighth Amendment’s prohibition of cruel and unusual punishment. The district court personally inspected SOCF and made detailed findings. These findings showed that SOCF was indeed double celling, although SOCF also had dayrooms, gyms, workshops, schoolrooms, and other facilities for prisoners to enjoy during the day. The findings also showed that although SOCF was experiencing an increased prisoner population, double celling was not leading to increased violence or depriving prisoners of medical care, food, or air conditioning. Despite these findings, the district court found that double celling violated the Eighth Amendment. The court of appeals affirmed, but it held that double celling was only unconstitutional at SOCF and not as a general practice. The Supreme Court granted certiorari to determine whether double celling was unconstitutional.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

Concurrence (Blackmun, J.)

Concurrence (Brennan, J.)

Dissent (Marshall, J.)

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