Inmates of the Allegheny County Jail v. Wecht

901 F.2d 1191, 1990 WL 44268
Court of Appeals for the Third Circuit·Decided April 19, 1990·No. No. 89-3565·Published·Cited by 11 cases

Opinion

OPINION OF THE COURT

A. LEON HIGGINBOTHAM, Jr., Chief Judge.

On June 2, 1976, the inmates of Allegheny County Jail, in Pittsburgh, Pennsylvania, commenced this action challenging the constitutionality of the conditions of their confinement. In the more than thirteen years since the inmates filed their complaint, Allegheny County has consistently failed to house its inmates in compliance with the sparse and minimal commands of the Eighth Amendment. Through much of this period, Allegheny County officials have also consistently violated court orders designed to remedy severe overcrowding at the jail.

In this appeal, county officials once again ask us to set aside sanctions resulting from their violation of court orders limiting the population at the Allegheny County Jail. Because we conclude that the district court did not commit legal error or abuse its discretion in imposing these fines, we will not disturb the order imposing sanctions. However, for the reasons set out below, we must vacate the attorneys’ fee award and remand for further proceedings on the inmates’ fee petition.

I. Background

The facts and procedural history of this case have been thoroughly chronicled in numerous reported decisions of the district court and this court.1 Owens-el v. Robinson, 442 F.Supp. 1368 (W.D.Pa.1978) (holding after six week trial that conditions at jail violated Constitution in several respects); Owensel v. Robinson, 457 F.Supp. 984 (W.D.Pa.1978) (ordering injunctive relief), aff'd in part and remanded in part sub nom. Inmates of Allegheny County v. Pierce, 612 F.2d 754 (3d Cir.1979), on remand, Inmates of Allegheny County v. Pierce, 487 F.Supp. 638 (W.D.Pa.1980) (holding after five day trial that care of mentally ill patients amounted to deliberate indifference, and ordering injunctive relief); Inmates of Allegheny County v. Pierce, 716 F.2d 177 (3d Cir.1983) (attorneys’ fee appeal); Inmates of Allegheny County Jail v. Wecht, 565 F.Supp. 1278 (W.D.Pa.1983) (holding that jail conditions violated prior injunctions in several respects, and that jail overcrowding violated constitution); Inmates of Allegheny County Jail v. Wecht, 573 F.Supp. 454 (W.D.Pa.1983) (finding that county was not meeting court-imposed jail population limits, ordering restrictions on housing of federal prisoners at jail, and ordering limited release of inmates held on low bail); Inmates of Allegheny County Jail v. Wecht, 754 F.2d 120 (3d Cir.1985) (affirming district court’s imposition of population limits and vacating sanctions); Inmates of Allegheny County Jail v. Wecht, 612 F.Supp. 874 (W.D.Pa.1985) (enjoining the long term detention in city lock-ups of female inmates committed [1193]*1193to the jail); Inmates of Allegheny County Jail v. Wecht, 699 F.Supp. 1137 (W.D.Pa.1988) (finding continuing constitutional violations at jail, imposing sanctions, ordering closing of jail and submission of plans for new or alternate facilities), aff'd in part, appeal dismissed in part, 874 F.2d 147 (3d Cir.), vacated and remanded, — U.S. -, 110 S.Ct. 355, 107 L.Ed.2d 343 (1989), on remand, 893 F.2d 33 (3d Cir.1990). Although our previous opinions at 754 F.2d 120 and 874 F.2d 147 describe many of the facts and proceedings relevant to the jail overcrowding issue, for the sake of clarity we will again summarize the pertinent background.

A. Jail Overcrowding Litigation: 1983 to January 1985

Since 1978, the appellants (hereafter, “defendants” 2) have been subject to various court orders designed to remedy the unconstitutional conditions at the jail. However, this case was seven years old before the overcrowding issue became the focus of judicial attention. On May 25, 1983, the district court found that the “dangerously overcrowded” status of the Allegheny County Jail was among the circumstances that made the jail “a catastrophe waiting to happen.” Inmates, 565 F.Supp. at 1281. The district court observed that overcrowding had a pervasive impact on many aspects of jail life — adversely affecting inmates’ safety and physical and psychological health, restricting recreational and educational activities, decreasing the ratio of staff to inmates, and generally increasing the level of tension at the facility. Id. at 1295.

The court also noted the county’s lack of interest in providing more prison space.

We take judicial notice of the fact that for years Allegheny County officials have proposed, rejected, discussed and haggled over new jail facilities; plans for new buildings have been drawn up; proposals for renovating already existing facilities have been made and rejected; other plans have been delayed in the hope that outside financial sources of assistance will be uncovered. As a result, the jail remains with us — old, dilapidated and unconstitutionally overcrowded. An economic motive can no longer excuse or be used to justify the conditions imposed on the inmates at [the Allegheny County Jail].

Id. at 1296-97.

To remedy the overcrowding, the district court on May 25, 1983 issued an order providing for the phased reduction of the jail population to 500 male and 30 female inmates by January 1, 1984. Supplemental Appendix (“Supp.App.”) at 30. No appeal was taken from that order.

Although the defendants initially complied with the terms of the May 25, 1983 order, the jail population soon exceeded the court-imposed population limits. On October 20, 1983, the district court denied the defendants’ motion for an extension of time to comply with the population limits and granted the inmates’ motion for additional relief to ensure observance of those limits. The court stated that “[ajlthough there has been some reduction in population, the dangerously overcrowded condition of the jail is just as serious today as it was on May 25, 1983.” Inmates, 573 F.Supp. at 457. The court did not impose sanctions against the defendants. Instead, it cut back on the housing of federal prisoners at the jail and ordered the defendants to meet the population cap by releasing inmates held in default of the lowest amount of bail. However, the court cautioned the defendants not to regard the release of low bail prisoners as a permanent measure. The court stated: “[i]t is the duty of the County to house prisoners, and any release of prisoners as a result of this order should be recognized as a final, albeit temporary, effort to ameliorate the situation, not as a solution to the problem.” Id.

By late December 1983, twenty six inmates had been released to comply with the population limits, and the county had made [1194]*1194no progress in obtaining interim or alternate facilities for inmates who could not be housed at the jail. On December 30, 1983, the district court issued an order providing, in part, that after February 15, 1984, the defendants would be fined $5,000 “for each prisoner released under the formula described in this Court’s Order of October 20, 1983.”3

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Inmates of the Allegheny County Jail v. Wecht, 901 F.2d 1191, 1990 WL 44268 (3d Cir. 1990).

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