Wolff v. McDonnell
In the Supreme Court of the United States
Argued April 22, 1974
Decided June 26, 1974
The plaintiff, an inmate on behalf of prisoners at the Nebraska prison filed a Section 1983 class action suit against prison officials (US Supreme Court, 1974).
Issue
In the suit, plaintiffs alleged that disciplinary measures at the facility contravened the due process; that the regulations concerning mail of inmates were unconstitutionally restrictive; and that the legal assistance program offered to inmates did not meet constitutional threshold (US Supreme Court, 1974).
Decision
The Supreme Court of the United States issued a 6-3 decision stating that the case of Wolff v. McDonnell should be affirmed or reversed in part and remanded upholding Fourteenth Amendment (Due Process) as constitutional (US Supreme Court, 1974).
Reasoning
The decision on Wolff v. McDonnell case was based on past judicial consideration of the due process notice hearing and controversy.
Procunier v. Martinez
Facts
Argued December 3, 1973
Decided April 29, 1974
The case of Procunier v. Martinez was about class of action suit brought by inmates challenging mail censorship regulations (US Supreme Court, 1974). They also wanted to ban against the use of law students and paralegals from conducting attorney-client interviews with inmates (US Supreme Court, 1974).
Issues
The class of action brought by prison inmates challenged mail censorship regulations issued by the Director of the California Department of Corrections. The plaintiffs also wanted to ban law students and legal professionals from conducting attorney-client-interviews with prison inmates (US Supreme Court, 1974). The censorship on mail regulated correspondence of inmates by determining what they deemed appropriate.
Decisions
The District Court held these regulations unconstitutional under the First Amendment and the 14th Amendments (US Supreme Court, 1974). The court also maintained that the ban against the use of law students and paralegals to conduct attorney-client interviews with prison inmates infringed the right of access to courts and enjoined its continued enforcement (US Supreme Court, 1974).
Reasoning
These regulations were held void for vagueness and violated the provisions of the due process. The court maintained that inmates must be notified in case of rejection of correspondence, and that the author of the correspondence be allowed to appeal the decision and secure review by another prison official other than the original censor (US Supreme Court, 1974).
Dissenting opinions
Opponents argue that the District Court should not have engaged in deciding the constitutionality of the mail censorship regulations (US Supreme Court, 1974).
Estelle v. Gamble
Facts
Argued: October 5, 1976
Decided: November 30, 1976
Gamble, a state inmate who injured his back during prison labor filed a lawsuit, claiming that he was subjected to unusual and cruel punishment in violation of the Eighth Amendment due to inadequate treatment for the injuries sustained while performing prison work (US Supreme Court, 1976). The case was dismissed by the District Court for failure to submit a claim upon which relief could be granted.
Decisions
The District Court dismissed the complaint for failure to state a claim for which failure could be granted. However, the United States Supreme Court held that the alleged insufficiency of the medical treatment required recall of the complaint (US Supreme Court, 1976).
Reasoning
Despite crediting complaint by Gamble that the doctors failed to provide adequate care, Gamble’s own factual account of the event of his treatment supported the doctor’s defense that they were not indifferent to him and treated him as best as they could (US Supreme Court, 1976).
Dissenting opinions
Despite crediting Gamble’s complaints regarding failure of doctors to provide him with adequate medical care, the court held that there was no medical malpractice to the level of “cruel and unusual punishment” simply because the victim was a prisoner (US Supreme Court, 1976).
Bell v. Wolfish
Facts
Argued January 16, 1979
Decided May 14, 1979
In the case, inmates of the Metropolitan Correctional Center (MCC) brought a class of action lawsuit to challenge unfavorable conditions of confinement and practices of MCC (US Supreme Court, 1979). The respondents challenged double banking, restriction on packages from outside, restrictions on reading materials, body-cavity searches, and requirements that inmates remain outside during searches (US Supreme Court, 1979).
Issues
Do the practices of MCC constitute punishments depriving inmates of their liberty without due process of law? (US Supreme Court, 1979). Do other practices of MCC violate constitutional rights of inmates? (US Supreme Court, 1979).
Decisions
The Supreme Court found that none of the procedures or policies violated the Fourth Amendment.
Reasoning
As explained by the majority, if a practice or policy is related to a legitimate government process, the court may presume it non-punitive (US Supreme Court, 1979).
Dissent
Justice Marshall dissented and according to him a balancing test would be appropriate for the due process claims in this case.
References:
US Supreme Court Center. Estelle v. Gamble - 429 U.S. 97 (1976). Justia.com. Retrieved from http://supreme.justia.com/cases/federal/us/429/97/case.html
US Supreme Court Center. Procunier v. Martinez - 416 U.S. 396 (1974). Justia.com. Retrieved from. http://supreme.justia.com/cases/federal/us/416/396/case.html
US Supreme Court Center. Bell v. Wolfish - 441 U.S. 520 (1979). Justia.com. Retrieved from http://supreme.justia.com/cases/federal/us/441/520/case.html
US Supreme Court Center. Wolff v. McDonnell - 418 U.S. 539 (1974). Justia.com. Retrieved from http://supreme.justia.com/cases/federal/us/418/539/
