Cases by Issue - Non-Death Penalty

Overton v. Bazzetta

Mon, 05 Jan 2009 17:48:05 +0000

Case Basics

Docket No.

02-94

Petitioner

Overton

Petitioner Type

Petitioner

Respondent

Bazzetta

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

539 U.S. 126 (2003)

Argued

Wednesday, March 26, 2003

Decided

Monday, June 16, 2003

Advocates

Thomas L. Casey (Lansing, Michigan, argued the cause for the petitioners)

Jeffrey A. Lamken (Department of Justice, argued the cause for the United States, as amicus curiae, supporting petitioners)

Deborah LaBelle (Argued the cause for the respondents)

Facts of the Case

In 1995, after the Michigan Department of Corrections (MDOC) banned visits to inmates by little brothers and sisters, nieces, nephews and other minors, a group of prisoners sued. They claimed that the ban violated the Due Process Clause of the Fourteenth Amendment and the Cruel and Unusual Punishment Clause of the Eighth Amendment, and that it restricted their First Amendment right to association. The district court agreed, ruling against the ban. On appeal, the 6th Circuit Court of Appeals unanimously affirmed the district court's ruling.

Question

Did the Department of Corrections ban on visits by minors violate the Due Process Clause of the Fourteenth Amendment, the Cruel and Unusual Punishment Clause of the Eighth Amendment and the freedom of association of the First Amendment?

Conclusion

Decision: 9 votes for Overton, 0 vote(s) against
Legal provision: Association

No. In a 9-0 opinion delivered by Justice Anthony M. Kennedy, the Court held that the MDOC's regulations were valid. The Court reasoned that the fact that the regulations bear a rational relation to legitimate penological interests suffices to sustain them regardless of whether the prisoners have a constitutional right of association that has survived incarceration. The Court also concluded that the visitation restriction for inmates with two substance- abuse violations is not a cruel and unusual confinement condition violating the Eighth Amendment. The Court reasoned that withdrawing visitation privileges for a limited period is not a dramatic departure from accepted standards for confinement conditions. Justice Clarence Thomas, joined by Justice Antonin Scalia, filed an opinion concurring in the judgment.

Ewing v. California

Mon, 20 Jun 2011 04:06:33 +0000

Location

El Segundo Golf Course

400 South Sepulveda Boulevard El Segundo CA 90245

El Segundo, CA 90245

United States

33° 54' 40.878" N, 118° 23' 37.8744" W

See map: Google Maps

Case Basics

Docket No.

01-6978

Petitioner

Gary Ewing

Petitioner Type

Petitioner

Respondent

California

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

538 U.S. 11 (2003)

Argued

Tuesday, November 5, 2002

Decided

Wednesday, March 5, 2003

Advocates

Michael Chertoff (for United States, as amicus curiae, supporting the Respondent)

Quin Denvir (on behalf of the Petitioner)

Donald E. De Nicola (on behalf of the Respondent)

Facts of the Case

On March 12, 2000, Gary Ewing, a serial offender with a long history of criminal convictions, was arrested for stealing three golf clubs, each worth $399, from a Los Angeles-area golf course. At the time of his arrest, Ewing was on parole from a 9-year prison term for convictions in three burglaries and one robbery. Under California's three strikes law, another felony conviction would require a sentence of 25 years to life. Ewing was charged with and convicted of one count of felony grand theft for the incident at the golf course. During sentencing, Ewing requested the judge in the case exercise discretion permitted under California law and reduce the conviction to a misdemeanor. The judge declined and sentenced Ewing in accordance with the three strikes law. On appeal, Ewing argued the sentence of 25 years to life was grossly disproportionate to the crime and therefore a violation of the Eighth Amendment protection against cruel and unusual punishments. The court, reasoning that the three strikes law served the state's legitimate interests, rejected this claim. The California Supreme Court declined to hear the case.

Question

Did Ewing's sentence of 25 years to life, in accordance with California's three strikes law, violate the Eighth Amendment protection against cruel and unusual punishment?

Conclusion

Decision: 5 votes for California, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

No. In a 5-4 plurality decision authored by Justice Sandra Day O'Connor, the Court, relying heavily on its decision in Rummel v. Estelle (1980), concluded that Ewing's long history of legal offenses justified his conviction. In Rummel, the Court had ruled that a sentence of life with the possibility of parole was valid for three convictions of fraud, check forgery, and theft. In that case, the Court gave great deference to legislatures in mandating sentences for repeat offenders. Justice O'Connor writes that, as in Rummel, Ewing's conviction reflects "rational legislative judgment" and "is justified by the State's public-safety interest in incapacitating and deterring recidivist felons."

Hope v. Pelzer

Mon, 05 Jan 2009 17:46:20 +0000

Case Basics

Docket No.

01-309

Petitioner

Hope

Petitioner Type

Petitioner

Respondent

Pelzer

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

536 U.S. 730 (2002)

Argued

Wednesday, April 17, 2002

Decided

Thursday, June 27, 2002

Advocates

Gene C. Schaerr (Argued the cause as amici curiae, supporting the respondents)

Austin C. Schlick (Argued the cause for the United States, as amicus curiae, supporting the petitioner)

Craig T. Jones (Argued the cause for the petitioner)

Nathan A. Forrester (Argued the cause for the respondents)

Facts of the Case

As an Alabama prison inmate, Larry Hope was twice handcuffed to a hitching post for disruptive conduct. Both times prison guards handcuffed Hope above shoulder height, and when he tried moving his arms to improve circulation, the handcuffs cut into his wrists. During the second incident, guards order Hope to remove his shirt and he spent seven hours on the hitching post in the sun. While there, he was given one or two water breaks, but no bathroom breaks. Hope filed a civil suit against the guards. Subsequently, a Magistrate Judge found that the guards were entitled to qualified immunity. Ultimately affirming, the Court of Appeals, while finding that the hitching post's use for punitive purposes violated the Eighth Amendment, concluded that the guards nevertheless entitled to qualified immunity.

Question

Does the Court of Appeals holding of qualified immunity where prison guards' conduct violated the Eighth Amendment comport with United States v. Lanier, 520 U.S. 259?

Conclusion

Decision: 6 votes for Hope, 3 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the defense of qualified immunity was precluded at the summary judgment phase of Hope's trial. The Court reasoned that, although Hope's allegations if true established an Eighth Amendment violation, prison guards could be shielded from liability for their constitutionally impermissible conduct if their actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Noting that United States v. Lanier makes clear that officials can be on notice that their conduct violates established law even in novel factual situations, the Court concluded that a reasonable officer would have known that using a hitching post as Hope alleged was unlawful.

United States v. Bajakajian

Mon, 05 Jan 2009 16:15:02 +0000

Case Basics

Docket No.

96-1487

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Bajakajian

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

524 U.S. 321 (1998)

Argued

Tuesday, November 4, 1997

Decided

Monday, June 22, 1998

Advocates

James E. Blatt (Argued the cause for the respondent)

Irving L. Gornstein (Department of Justice, argued the cause for the petitioner)

Facts of the Case

During a routine check of departing international flight passengers, customs officers discovered $357,144 on the person of Hosep Bajakajian. In addition to charging him, under 31 U.S.C. Section 5316, of attempting to leave the United States with an unreported sum in excess of $10,000 cash, the government also sought forfeiture of the entire $357,144 under 18 U.S.C. Section 982 providing that the deliberate violation of Section 5316 shall result in the forfeiture of "any property involved in such an offense." After having its forfeiture claim rejected in both a district court and the Ninth Circuit, as excessively unconstitutional, the Supreme Court granted the government certiorari.

Question

Is the forfeiture of $357,144 cash, a sum involved in the offense of failure to report property in excess of $10,000 while attempting to leave the country, a violation of the Eighth Amendment's Excessive Fines Clause?

Conclusion

Decision: 5 votes for Bajakajian, 4 vote(s) against
Legal provision: 18 U.S.C. 982

Yes. In a 5-to-4 opinion, the Court held that the government's ability to extract fines is limited by the Excessive Fines Clause. The forfeiture of currency, when ordered for a violation of a reporting statute, is a punitive measure which constitutes a "fine" under the Eighth Amendment. Noting the importance of making punishments proportional to their crimes, the Court reminded that currency transportation is generally permissible. Bajakajian's failure to do so within statutory reporting guidelines was neither related to other illegal activity nor did it result in loss to the government. Therefore, forfeiture of the entire sum would be grossly disproportional to the gravity of his offense.

Farmer v. Brennan, Warden

Mon, 05 Jan 2009 16:23:46 +0000

Case Basics

Docket No.

92-7247

Petitioner

Farmer

Petitioner Type

Petitioner

Respondent

Brennan, Warden, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1993-1994)

Decided By

Rehnquist Court (1993-1994)

Opinion

511 U.S. 825 (1994)

Argued

Wednesday, January 12, 1994

Decided

Monday, June 6, 1994

Advocates

Paul Bender (on behalf of the Respondents)

Elizabeth Alexander (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Farmer, 0 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Austin v. United States

Mon, 05 Jan 2009 16:01:13 +0000

Case Basics

Docket No.

92-6073

Petitioner

Austin

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

509 U.S. 602 (1993)

Argued

Tuesday, April 20, 1993

Decided

Monday, June 28, 1993

Advocates

Miguel A. Estrada (on behalf of the Respondent)

Richard L. Johnson (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Austin, 0 vote(s) against
Legal provision: 21 U.S.C. 881

None

Helling v. McKinney

Mon, 05 Jan 2009 16:00:53 +0000

Case Basics

Docket No.

91-1958

Petitioner

Helling

Respondent

McKinney

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

509 U.S. 25 (1993)

Argued

Wednesday, January 13, 1993

Decided

Friday, June 18, 1993

Advocates

Frankie Sue Del Papa (Argued the case for the petitioners)

John G. Roberts, Jr. (Argued the case as amicus curiae urging reversal)

Cornish F. Hitchcock (Argued the case for the respondents)

Facts of the Case

William McKinney, a Nevada state prisoner, sued his warden and several other prison officials for violating his Eighth Amendment rights by subjecting him to unhealthy levels of second-hand smoke. McKinney shared a cell with a man who smoked five packs of cigarettes a day. He claimed that his health - both current and future - was being harmed by the smoke, and that the prison officials were "deliberately indifferent" to the risk in violation of the Supreme Court's decision in Wilson v. Seiter, 501 U.S. 294. After a federal magistrate ruled that he did not have an Eighth Amendment right to a smoke- free environment and that he had failed to prove any "serious medical needs," the Ninth Circuit Court of Appeals reversed, holding that he should have been given another opportunity to prove that the smoke levels were sufficient to constitute an unreasonable danger to his future health.

Question

May an inmate sue to prove that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by prison officials who act with "deliberate indifference" to the future health risks associated with second-hand smoke?

Conclusion

Decision: 7 votes for McKinney, 2 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

Yes. In a 7-to-2 decision, the Supreme Court held that McKinney's suit stated a reasonable claim that, if proven, could be grounds for relief under the Eighth Amendment prohibition of cruel and unusual punishment. Justice Byron White, in the majority opinion, rejected the government's argument that the "deliberate indifference" test established by the Court in Wilson (which held that withholding medical care from prisoners only violated the Eighth Amendment if it was done with "deliberate indifference" to serious health risks) only applied to current medical conditions. If McKinney could prove that the second-hand smoke posed a serious threat to his future health and that the prison officials had deliberately ignored that threat, White wrote, McKinney would be entitled to relief.

Alexander v. United States

Mon, 20 Jun 2011 04:06:26 +0000

Location

City of Minneapolis

300 South Fourth Street Minneapolis MN 55415

Minneapolis, MN 55415

United States

44° 58' 41.6388" N, 93° 15' 52.9236" W

See map: Google Maps

Case Basics

Docket No.

91-1526

Petitioner

Ferris Alexander

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

509 U.S. 544 (1993)

Argued

Tuesday, January 12, 1993

Decided

Monday, June 28, 1993

Advocates

Kenneth W. Starr (on behalf of the Respondent)

John H. Weston (on behalf of the Petitioner)

Facts of the Case

Ferris Alexander was the owner of a chain of stores and theaters in Minnesota that distributed sexually explicit media. He was charged with violating federal obscenity laws and the Racketeer Influenced and Corrupt Organizations Act (RICO). The federal District Court in Minnesota found him guilty of both charges. The court ordered him to forfeit his businesses, sentenced him to a six-year prison term, and fined him $100,000.

Alexander appealed, claiming that the confiscation of his stores for his dealings in obscene material amounted to 'prior restraint' on his subsequent distribution of adult materials, and therefore violated his First Amendment rights. He also claimed that the seizure of his business violated his Eighth Amendment protection against excessive fines. The United States Court of Appeals for the Eighth Circuit affirmed the District Court's judgment on the First Amendment claim, and declined to review the Eighth Amendment claim on the ground that no sentence less severe than life imprisonment without parole could justify an Eighth Amendment review.

Question

Does property forfeiture under RICO as punishment for the distribution of obscene materials constitute 'prior restraint' on speech in violation of the First Amendment?
Does the forfeiture of a business as punishment for the sale of obscene media constitute an 'excessive fine'?

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: Prohibition of Excessive Fines

No and undecided. Chief Justice William Rehnquist wrote for a 5-4 majority that the application of RICO in Alexander's case was neither a 'prior restraint' on speech, nor a criminalization of speech typically protected under the Constitution. His sentence established no conditions on his behavior after its completion; once he paid the fine, surrendered his business and went to prison, he could theoretically distribute adult media without prejudice from the government. "To accept petitioner's argument," Rehnquist wrote, "would virtually obliterate the distinction [...] between prior restraints and subsequent punishments."

In a separate and unanimous vote, the Court ruled that the forfeiture did in fact merit Eighth Amendment review. The case was returned to the Eighth Circuit for an analysis under the Excessive Fines Clause.

Hudson v. McMillian

Mon, 20 Jun 2011 04:06:25 +0000

Location

Angola Louisiana State Penitentiary

Highway 66 Angola LA

Angola, LA

United States

30° 57' 47.9952" N, 91° 35' 48.4584" W

See map: Google Maps

Case Basics

Docket No.

90-6531

Petitioner

Hudson

Respondent

McMillian

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

503 U.S. 1 (1992)

Argued

Wednesday, November 13, 1991

Decided

Tuesday, February 25, 1992

Advocates

Alvin J. Bronstein (Argued the case for the petitioner)

John G. Roberts, Jr. (Argued the case for the United States as amicus curiae urging reversal )

Harry McCall, Jr. (Argued the case for respondents)

Facts of the Case

Keith Hudson, a Louisiana inmate, claimed that he was beaten by Marvin Woods and Jack McMillian, two prison guards, while their supervisor, Arthur Mezo, watched. Hudson sued the guards in Federal District Court under 42 U.S.C. 1983, which allows individuals to bring suit for the "deprivation of any rights, privileges, or immunities secured by the Constitution." Hudson argued that they had violated his Eighth Amendment right to be free from cruel and unusual punishment. The District Court ruled that the guards had used force when there was no need to do so, violating the Eighth Amendment, and that Hudson was therefore entitled to damages. The Fifth Circuit Court of Appeals reversed, however, finding that an inmate must demonstrate "significant injury" when he claims that his Eighth Amendment rights have been violated by the use of excessive force.

Question

Must an inmate alleging that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by the excessive use of force demonstrate "significant injury" to prevail on his claim?

Conclusion

Decision: 7 votes for Hudson, 2 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

No. In a 6-to-3 decision, the Supreme Court held that the degree of injury suffered by an inmate is one of several important factors in an Eighth Amendment claim of cruel and unusual punishment, but that the absence of "significant injury" alone does not mean his rights have not been violated. Instead, the Court should consider whether the punishment inflicted was malicious and sadistic. "When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency are always violated," Justice Sandra Day O'Connor wrote in the majority opinion. "This is true whether or not significant injury is evident. Otherwise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury. Such a result would have been as unacceptable to the drafters of the Eighth Amendment as it is today."

Wilson v. Seiter

Mon, 20 Jun 2011 04:06:23 +0000

Location

Hocking Correctional Facility

16759 Snake Hollow Rd Nelsonville OH 45764

Nelsonville, OH 45764

United States

39° 28' 24.6324" N, 82° 13' 35.0616" W

See map: Google Maps

Case Basics

Docket No.

89-7376

Petitioner

Pearly L. Wilson

Petitioner Type

Petitioner

Respondent

Richard Seiter et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1990-1991)

Opinion

501 U.S. 294 (1991)

Argued

Monday, January 7, 1991

Decided

Monday, June 17, 1991

Advocates

Elizabeth Alexander (argued the cause for the petitioner)

William C. Bryson (Deputy Solicitor General, Department of Justice, argued the cause on behalf of the United States, as amicus curiae, supporting the petitioner)

Rita S. Eppler (Assistant Attorney General of Ohio, argued the cause for the respondent)

Facts of the Case

While detained at the Hocking Correctional Facility in Nelsonville, Ohio, Pearly Wilson claimed he experienced cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. Wilson sought financial awards and an injunction against the prison under 42 U.S.C. 1983. He filed suit in a federal district court against two state prison officials, Richard P. Seiter and Carl Humphreys. The District Court ruled against Wilson, and the United States Court of Appeals for the Sixth Circuit affirmed. It held that Wilson had to show that the prison officials had a "culpable state of mind" when inflicting harm upon him.

Question

Did the United States Court of Appeals for the Sixth Circuit err by holding that prison officials must have a "culpable state of mind" in order to establish cruel and unusual punishment of an inmate? Did the Court of Appeals err by overlooking an inmate's claim that prison officials showed "deliberate indifference" to his conditions of confinement?

Conclusion

Decision: 5 votes for Seiter, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

No and Yes. Justice Antonin Scalia delivered the opinion for a unanimous court. The Court referred to its earlier decisions in Francis v. Resweber and Estelle v. Gamble to establish that cruel and unusual punishment required the "unnecessary and wanton infliction of pain." For this to occur, the prison officials had to exhibit intentional cruelty, which would result in a "culpable state of mind." However, "deliberate indifference" to a prisoner's conditions also constituted abusive treatment according to this standard. Therefore the Court of Appeals should have considered this aspect of Wilson's grievances.

Harmelin v. Michigan

Mon, 20 Jun 2011 04:06:23 +0000

Location

Harmelin's Car

W 8 Mile Rd Oak Park MI 48237

Oak Park, MI 48237

United States

42° 26' 43.5768" N, 83° 11' 18.7476" W

See map: Google Maps

Case Basics

Docket No.

89-7272

Petitioner

Harmelin

Petitioner Type

Petitioner

Respondent

Michigan

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1991)

Opinion

501 U.S. 957 (1991)

Argued

Monday, November 5, 1990

Decided

Thursday, June 27, 1991

Advocates

Richard Thompson (Argued the cause for the respondent)

Carla J. Johnson (By appointment of the Court, argued the cause for the petitioner)

Facts of the Case

Following his conviction under Michigan law for possession of over 650 grams of cocaine, Ronald Harmelin was sentenced to life in prison without possibility of parole. Harmelin challenged his sentence as cruel and unusual, claiming it was disproportionate to the crime he committed and was statutorily mandated without consideration for the fact that he had no prior felony convictions. On appeal from an affirmance by the Michigan Court of Appeals, the Supreme Court granted certiorari.

Question

Is a statutorily mandated sentence that does not allow for consideration of mitigating factors a violation of the Eighth Amendment's protection against cruel and unusual punishments?

Conclusion

Decision: 5 votes for Michigan, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

No. The Court, in a 5-to-4 decision, held that since the Eighth Amendment does not contain a proportionality guarantee, the determination of whether a punishment is "cruel and unusual" is not made with reference to the particular offense. Moreover, the Cruel and Unusual Punishment Clause protects against unusual methods of punishment, not necessarily cruel ones. As such, while Harmelin's life sentence may have been cruel, it was not constitutionally unusual or unprecedented.

Whitley v. Albers

Mon, 05 Jan 2009 17:27:25 +0000

Case Basics

Docket No.

84-1077

Petitioner

Whitley

Petitioner Type

Petitioner

Respondent

Albers

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

475 U.S. 312 (1986)

Argued

Tuesday, December 10, 1985

Decided

Tuesday, March 4, 1986

Advocates

Gene B. Mechanic (on behalf of the Respondent)

Dave Frohnmayer (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Whitley, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Solem v. Helm

Mon, 05 Jan 2009 17:32:58 +0000

Case Basics

Docket No.

82-492

Petitioner

Solem

Petitioner Type

Petitioner

Respondent

Helm

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

463 U.S. 277 (1983)

Argued

Tuesday, March 29, 1983

Decided

Tuesday, June 28, 1983

Advocates

John J. Burnett (By appointment of the Court, argued the cause for the respondent)

Mark V. Meierhenry (Argued the cause for the petitioner)

Facts of the Case

Helm was convicted of writing a check from a fictitious account, a crime carrying with it a five-year jail sentence. However, since this was his seventh felony conviction in South Dakota since 1964, he was sentenced to life imprisonment without parole under a state recidivist statute.

Question

Did the sentence violate the Eighth and Fourteenth Amendments?

Conclusion

Decision: 5 votes for Helm, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

Yes. Since all of Helm's prior offenses, including his current check-writing conviction, had been "relatively minor" and were not crimes against people, Justice Powell held that Helm had "received the penultimate sentence (South Dakota did not have the death penalty) for relatively minor criminal conduct." Powell concluded that Helm was treated more harshly than the state's most violent criminals.

Rhodes v. Chapman

Mon, 05 Jan 2009 17:28:32 +0000

Case Basics

Docket No.

80-332

Petitioner

Rhodes

Petitioner Type

Petitioner

Respondent

Chapman

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

452 U.S. 337 (1981)

Argued

Monday, March 2, 1981

Decided

Monday, June 15, 1981

Advocates

Jean P. Kamp (on behalf of the Respondents)

Allen P. Adler (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Rhodes, 1 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Rummel v. Estelle

Mon, 20 Jun 2011 04:06:14 +0000

Location

U.S. District Court for the Western District of Texas, San Antonio Division

655 East Durango Blvd. San Antonio TX 78206

San Antonio, TX 78206

United States

29° 25' 5.016" N, 98° 29' 10.0032" W

See map: Google Maps

Case Basics

Docket No.

78-6386

Petitioner

Rummel

Petitioner Type

Petitioner

Respondent

Estelle

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

445 U.S. 263 (1980)

Argued

Monday, January 7, 1980

Decided

Tuesday, March 18, 1980

Advocates

Douglas M. Becker (Argued the cause for the respondent)

Scott J. Atlas (By appointment of the Court, argued the cause for the petitioner)

Facts of the Case

After being convicted of three felonies over a period of fifteen years, William James Rummel was given a life prison sentence as mandated by a Texas recidivist statute. Rummel's offenses involved approximately $230, and all of the offenses were nonviolent. Lower courts rejected Rummel's challenge to the sentence.

Question

Did Rummel's life sentence under the Texas recidivist law constitute cruel and unusual punishment in violation of the Eighth Amendment?

Conclusion

Decision: 5 votes for Estelle, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

In a 5-to-4 decision, the Court held that the life sentence imposed by Texas law did not constitute cruel and unusual punishment under the Eighth and Fourteenth Amendments. The Court held that Texas had a significant interest in dealing "in a harsher manner with those who by repeated criminal acts have shown that they are simply incapable of conforming to the norms of society." The Court also noted that Texas had "a relatively liberal policy of granting 'good time' credits to its prisoners," indicating that there was a possibility that Rummel would not be imprisoned for the rest of his life.

Hutto v. Finney

Mon, 05 Jan 2009 16:33:59 +0000

Case Basics

Docket No.

76-1660

Petitioner

Hutto

Petitioner Type

Petitioner

Respondent

Finney

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

437 U.S. 678 (1978)

Argued

Tuesday, February 21, 1978

Decided

Friday, June 23, 1978

Advocates

Philip E. Kaplan (Argued the cause for the respondents)

Garner L. Taylor, Jr. (Argued the cause for the petitioners)

Facts of the Case

Litigation challenging the conditions in the Arkansas prison system began in 1969. In evaluating the diet and sleeping arrangements of the inmates, the physical condition of cells, and the behavior of prison guards (some of whom were inmates who had been issued guns), a District Court called the conditions which inmates were forced to face "a dark and evil world completely alien to the free world." This case involved a challenge to the practice of "punitive isolation" in Arkansas prisons which was often done for indiscriminate periods of time in crowded windowless cells.

Question

Did punitive isolation for more than thirty days in the Arkansas prison system constitute cruel and unusual punishment as prohibited by the Eighth and Fourteenth Amendments?

Conclusion

Decision: 5 votes for Finney, 4 vote(s) against
Legal provision: Civil Rights Attorney's Fees Awards

The Court held that punitive isolation for longer than thirty days in Arkansas prisons constituted cruel and unusual punishment and violated the Constitution. Justice Stevens conceded that isolation in and of itself was not necessarily unconstitutional and may in fact serve an important, legitimate interest in administering a prison. However, when taken as a whole, continued Stevens, the conditions in Arkansas's prisons, combined with the severe risks to an inmate's health and safety which accompanied confinement in isolation, did constitute cruel and unusual punishment. "A filthy, overcrowded cell and a diet of 'gruel' might be tolerated for a few days and be intolerably cruel for weeks or months," Stevens concluded.

Ingraham v. Wright

Mon, 05 Jan 2009 17:10:38 +0000

Case Basics

Docket No.

75-6527

Petitioner

Ingraham

Petitioner Type

Petitioner

Respondent

Wright

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

430 U.S. 651 (1977)

Argued

November 2-3, 1976

Decided

Tuesday, April 19, 1977

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Wright, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Estelle v. Gamble

Mon, 05 Jan 2009 17:10:07 +0000

Case Basics

Docket No.

75-929

Petitioner

Estelle

Petitioner Type

Petitioner

Respondent

Gamble

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

429 U.S. 97 (1976)

Argued

Tuesday, October 5, 1976

Decided

Tuesday, November 30, 1976

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Estelle, 1 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Powell v. Texas

Mon, 05 Jan 2009 17:41:19 +0000

Case Basics

Docket No.

405

Appellee

Texas

Petitioner Type

Appellee

Appellant

Powell

Respondent Type

Appellant

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

392 U.S. 514 (1968)

Argued

Thursday, March 7, 1968

Decided

Monday, June 17, 1968

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Texas, 4 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

None

Robinson v. California

Mon, 20 Jun 2011 04:05:59 +0000

Location

Place of arrest

West Pico Boulevard Los Angeles CA 90006

Los Angeles, CA 90006

United States

34° 2' 49.9092" N, 118° 18' 32.58" W

See map: Google Maps

Case Basics

Docket No.

554

Appellee

California

Petitioner Type

Appellee

Appellant

Robinson

Respondent Type

Appellant

Heard By

Warren Court (1962)

Decided By

Warren Court (1962)

Opinion

370 U.S. 660 (1962)

Argued

Tuesday, April 17, 1962

Decided

Monday, June 25, 1962

Advocates

Samuel Carter McMorris (Argued the cause for the appellant)

William E. Doran (Argued the cause for the appellee)

Facts of the Case

A California statute made it a criminal offense for a person to "be addicted to the use of narcotics." Lawrence Robinson was convicted under the law, which required a sentence of at least ninety days in jail. A state appellate court affirmed Robinson's conviction on appeal.

Question

Was the California law an infliction of cruel and unusual punishment prohibited by the Eighth Amendment?

Conclusion

Decision: 6 votes for Robinson, 2 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

In a 6-to-2 decision, the Court held that laws imprisoning persons afflicted with the "illness" of narcotic addiction inflicted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The Court likened the law to one making it a criminal offense "to be mentally ill, or a leper, or to be afflicted with a venereal disease," and argued that the state could not punish persons merely because of their "status" of addiction. The Court noted that the law was not aimed at the purchase, sale, or possession of illegal drugs.