Ruiz v. United States

243 F.3d 941, 2001 WL 215694
CourtCourt of Appeals for the Fifth Circuit
DecidedMarch 23, 2001
Docket99-20228
StatusPublished
Cited by29 cases

This text of 243 F.3d 941 (Ruiz v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ruiz v. United States, 243 F.3d 941, 2001 WL 215694 (5th Cir. 2001).

Opinions

CARL E. STEWART, Circuit Judge:

Texas prison officials appeal from the district court’s denial of their motions to terminate prospective relief pursuant to 18 U.S.C. §§ 3626(b)(1) and (b)(2). For the following reasons, we reverse and remand.

FACTUAL AND PROCEDURAL BACKGROUND

The almost 30-year history of this case is well known within this circuit. In 1972, David Ruiz and other inmates (“inmates”) filed civil rights claims pursuant to 42 U.S.C. § 1983 against the director of the Texas Department of Corrections (“TDC”), seeking declaratory and injunctive relief for unconstitutional conditions and practices. The claims were consolidated and certified as a class in 1974, and in 1980, the district court issued an opinion finding numerous constitutional violations. The court issued a consent decree in 1981 that this Court affirmed in part in 1982. The parties continued to modify the remedial measures, and ultimately, the district court approved a proposed judgment by the parties in 1992. This judgment replaced previous orders and compliance plans and resulted in the termination of the district court’s jurisdiction in certain substantive areas. However, the court retained jurisdiction in other areas.

On March 25, 1996, the director of the Institutional Division of the Texas Department of Criminal Justice (“TDCJ-ID”)1 and members of the Texas Board of Criminal Justice (“the defendants”), filed a motion to vacate the 1992 judgment pursuant to Fed.R.Civ.P. 60(b)(5).2 One month later, on April 26, 1996, Congress enacted the Prison Litigation Reform Act (“PLRA”). Under the PLRA, federal courts may grant or terminate prospective relief in prison litigation, subject to delineated standards. See 18 U.S.C. § 3626. Courts may refuse to terminate prospective relief only upon making specific findings regarding the continued necessity of such relief. See id.

[944]*944Following the enactment of the PLRA, the defendants filed a motion to terminate the 1992 consent decree pursuant to 18 U.S.C. § 3626(b)(2), which provides for the immediate termination of prospective relief.3 Specifically, § 3626(b)(2) provides:

(2) Immediate termination of prospective relief. In any civil action with respect to prison conditions, a defendant or intervener shall be entitled to the immediate termination of any prospective relief if the relief was approved or granted in the absence of a finding by the court that the relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.

18 U.S.C. § 3626(b)(2). Two years after the enactment of the PLRA, the defendants filed a subsequent motion under § 3626(b)(l)(A)(iii), the two-year termination provision of the PLRA. That section provides:

(1) Termination of prospective relief...
(A) In any civil action with respect to prison conditions in which prospective relief is ordered, such relief shall be terminable upon the motion of any party or intervener ...
(iii) in the case of an order issued on or before the date of enactment of the Prison Litigation Reform Act, 2 years after such date of enactment.

18 U.S.C. § 3626(b)(l)(A)(iii). Both termination provisions, pursuant to which the defendants filed their motions, are subject to a limitation provision, which states:

(3) Limitation. Prospective relief shall not terminate if the court makes written findings based on the record that prospective relief remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary to correct the violation of the Federal right, and that the prospective relief is narrowly drawn and the least intrusive means to correct the violation.

18 U.S.C. § 3626(b)(3).

After various disputes, which included appeals to this Court, on March 1, 1999, the district court declared that the PLRA’s termination provisions violate separation of powers principles and due process.4 Alternatively, the court found that TDCJ-ID suffers from systemwide constitutional violations in the areas of inmate protection, use of force, and administrative segregation. The court made the alternative findings in the event this Court finds the PLRA’s termination provisions constitu-, tional. The court did not find constitutional violations in the areas of medical and psychiatric care.

On appeal, the defendants and the United States as Intervener-Plaintiff-Appel-lee-Cross-Appellant argue that the district court erred in finding the termination provisions of the PLRA unconstitutional. The defendants also contend that the district court erred in its alternative finding of systemwide constitutional violations. [945]*945The inmates claim that this Court does not have jurisdiction over the alternative order and, if it does, the district court erred in finding no constitutional violations in the areas of medical and psychiatric care.

DISCUSSION

I. Jurisdiction

This Court asked the parties to brief the issue of our jurisdiction to hear the appeal of the district court’s order denying the defendants’ motions to terminate the 1992 consent decree. The defendants and the inmates agree that this Court has jurisdiction over the denial of the motions to terminate on constitutional grounds under 28 U.S.C. § 1292(a)(1)5 as a refusal to dissolve an injunction. However, the inmates argue that the findings of Eighth Amendment violations in the areas of protection from harm, use of force, and administrative segregation are not appeal-able because they are a basis for directing the parties to confer and attempt to reach an agreement on a form of judgment remedying the violations, not a basis for denial of the motions. The inmates further contend that the contingent alternative order is not appealable because it will become effective only if this Court reverses the district court’s decision on the statutory and constitutional issues. According to the inmates, the alternative order merely establishes a process for replacing the final judgment with prospective injunctive relief and is only a predecessor to a final decree.

Both the primary and alternative orders give the parties an opportunity to attempt to reach an agreement on a proposed form of judgment. Thus, the inmates’ argument that the alternative order is somehow different. in this respect is unavailing.

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Bluebook (online)
243 F.3d 941, 2001 WL 215694, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruiz-v-united-states-ca5-2001.