Here’s my listing of the Top 10 United States Supreme Court cases involving prisoner civil rights. As a bonus, I’m also including an eleventh case frequently ignored by prisoners.
Most cases challenging prisoner rights are filed by prisoners themselves under 42 U.S.C. §1983. To learn more about how this statute is used by prisoners, read my post, Section 1983 and inmate rights.
My study and experience indicates that most lawsuits relate to healthcare. After healthcare, prisoner filings usually challenge various confinement issues, disciplinary procedures, prison or jail rules and regulations, religious rights and access to the court violations.
It’s surprising how many prisoners refuse to follow, or fail to exhaust, their facility’s grievance system before submitting a complaint to the court. Exhaustion isn’t a “suggestion” before filing a suit, it’s mandatory in all but a few situations. So, I’ve included cases covering exhaustion requirements due to their importance. Now my list:
Top 5 Supreme Court Cases Involving Prisoner Rights
Case #1: Estelle v. Gamble, 97 S.Ct. 285 (1976)
The Eighth Amendment is meant to prohibit “unnecessary and wanton infliction of pain” which is “repugnant to the conscience of mankind.”
The failure of correctional officials to provide inmates with adequate medical care may offend the Eighth Amendment if their “acts or omissions [are] sufficiently harmful to evidence deliberate indifference to serious medical needs.”
To prove an Eighth Amendment violation, a prisoner must satisfy both of two prongs: 1) an objective prong that requires proof of a serious medical need and, 2) a subjective prong that mandates a showing of prison administrators’ deliberate indifference to that need.
Deliberate indifference in this context may be shown by the denial of needed care as punishment and by decisions about medical care made recklessly with “actual knowledge of impeding harm, easily preventable.”
Case #2: Farmer v. Brennan, 114 S.Ct. 1970 (1994)
“The Constitution does not mandate comfortable prisons, neither does it permit inhumane ones.”
In this case, the Court held under the Eight Amendment, prison officials have a duty to protect prisoners from violence at the hands of other prisoners.
Not every injury suffered at the hands of another will result in constitutional liability on the part of prison officials. In this case, the Court established that only “deliberate indifference” by prison officials is sufficient to establish liability. The test for finding deliberate indifference consists of two parts.
First, the deprivation alleged must be, objectively, sufficiently serious. For a claim based on failure to prevent harm, the plaintiff must demonstrate he was incarcerated under conditions imposing a substantial risk of serious harm.
Second, the plaintiff must show that prison officials possessed a sufficiently culpable state of mind, namely one of deliberate indifference to an inmates health or safety. This may be accomplished by showing the prison official acted, or failed to act, with deliberate indifference to one’s health or safety. Mere inadvertence or negligence does not violate the Eighth Amendment.
The “deliberate indifference” test noted in Farmer applies to prison officials who fail to provide adequate medical care to the prisoner and other Eight Amendment style claims.
Case #3: Wolff v. McDonnell, 94 S.Ct. 2963 (1974)
Prisoners “may claim the protections of the Due Process Clause. They may not be deprived of life, liberty, or property, without due process of law.”
The Constitution does not mandate that disciplinary hearings for prison inmates provide the full range of procedures required in criminal proceedings. However, within the prison setting, there must be a mutual accommodation between the institutional needs and applicable Constitutional provisions.
Wolff established a prisoner facing a disciplinary hearing which may result in the loss of liberty or property interest must receive: 1) advance written notice of the disciplinary charges no less than 24 hours before the hearing 2) the opportunity to appear at the hearing, when consistent with institutional safety and correctional goals, to call witnesses and present documentary evidence in his defense and 3) a written statement by the factfinder of the evidence relied on and the reason for the disciplinary action.
Case #4: Sandin v. Conner, 115 S.Ct. 2293 (1995)
When litigating a due process denial, a prisoner must also prove an “atypical and significant hardship.. in relation to the ordinary incidents of prison life” or that the violation “will inevitably affect the duration of sentence.”
While Wolff defined the prison disciplinary due process procedure, Sandin subsequently held that any denial of due process claim must focus on whether the alleged violation imposes an atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life or inevitably affects the duration of the prisoner’s sentence.
Sandin severely restricted when a prisoner can successfully challenge a due process violation. Unless the due process violation resulted in a prison hardship or extended the duration of incarceration, a prisoner will likely be unable to successfully litigate a due process violation.
While a prisoner’s temporary loss of email, commissary or visits may be inconvenient, such a loss would not be considered a “hardship” under Sandin’s heightened requirements.
Case #5: Superintendent, Mass. Corr. Inst. v. Hill, 105 S.Ct. 2768 (1985)
“Due process requires procedural protections before a prison inmate can be deprived of a protected liberty interest in good time credits.”
The Court held that due process requires the procedural protections outlined in Wolff must be followed before a prisoner can be deprived of good time credits. In addition, the Court also held that due process requires “that there be some evidence to support the findings made in the disciplinary hearing.”
The Court reasoned that requiring a modicum of evidence to support a decision will help prevent arbitrary deprivations without threatening institutional interests or imposing undue administrative burdens.
The “some evidence” standard “does not require examination of the entire record, independent assessment of the credibility of witnesses, or weighing of the evidence. Instead, the relevant question is whether there is any evidence in the record that could support the conclusion reached be the disciplinary board.” Subsequently, the “some evidence” standard is not a high one.
Top 6-10 Supreme Court Cases Involving Prisoner Rights
Case #6: Turner v. Safley, 107 S.Ct. 2254 (1987)
A prison regulation “is valid if it is reasonably related to legitimate penological interests.”
In this case, the Court recognized that imprisonment does not automatically deprive a prisoner of certain important constitutional protections, including those of the First Amendment. But at the same time, the Constitution sometimes permits a greater restriction of rights in a prison than it would allow elsewhere.
The Court identified four relevant factors to consider in deciding whether a prison regulation withstands a constitutional challenge: 1) whether the regulation has a valid rational connection to a legitimate government interest 2) whether alternative means are open to inmates to exercise the asserted right 3) what impact an accommodation of the right would have on guards and inmates and prison resources and 4) whether there are already alternatives to the regulation.
The Court acknowledged running a prison is an inordinately difficult undertaking that requires expertise, planning, and the commitment of resources, all of which are peculiarly within the province of the legislative and executive branches of government. Prison administration is a task that has been committed to the responsibility of those branches, and separation of powers suggests a policy of judicial restraint.
What Turner allows, as long as a prison can supply a valid security reasoning for implementing a policy restricting a Constitutional right, courts will generally accept the prison’s reasoning for the restriction.
Case #7: Cutter v. Wilkinson, 125 S.Ct. 2113 (2005)
The First Amendment provides that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.”
Applicable to prisoners, Congress enacted the Religious Land Use and Institutionalized Persons Act (RLUIPA). 42 U.S.C. 2000cc-1(a). The statute provides:
“No government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution… even if the burden results from a rule of general applicability, unless the government demonstrates that imposition of the burden on that person-
- is in furtherance of a compelling governmental interest and
- is the least restrictive means of furthering that compelling governmental interest.”
For a prisoner to show one’s rights under RLUIPA are being violated, a claimant must first establish that the defendant’s policy or action creates a substantial burden on the exercise of his or her religious beliefs. Once the claimant makes such a showing, the defendant must come forward with evidence demonstrating that the burden furthers a compelling governmental interest and does so by the least restrictive means.
RLUIPA isn’t intended to elevate the accommodation of religious observances over an institution’s need to maintain order and safety. Courts applying the RLUIPA standard when evaluating a prison’s policy or action should give due deference to the experience and expertise of prison administrators in establishing necessary regulations and procedures to maintain good order, security and discipline, consistent with consideration of costs and limited resources.
Although RLUIPA bars inquiry into whether a particular belief or practice is central to a prisoner’s religion, during litigation, the act will not preclude inquiry into the sincerity of a prisoner’s professed religiosity.
Case #8: Lewis v. Casey, 116 S.Ct. 2174 (1996)
“[T]he fundamental constitutional right of access to the courts requires prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.”
While prisoners maintain a right of access to the courts, the right was significantly curtailed following this case. When considering an access to the court claim based on the alleged inadequacy of the prison law library and available legal assistance services, the plaintiff must show that the defendants actually injured him.
A plaintiff cannot merely allege that prison administrators provided insufficient access to law materials, a law library or law computer. The Court made clear that a prison isn’t required to “enable a prisoner to discover grievances, and litigate effectively once in court.”
Rather, to state a claim, a plaintiff must allege facts showing he was actually injured in his ability to pursue a nonfrivolous claim in a post-conviction proceeding or other civil rights matter that the plaintiff had a right to litigate.
Case #9: Porter v. Nussle, 122 S.Ct. 983 (2002)
“The Prison Litigation Reform Act’s exhaustion requirement applies to all inmate suits regarding prison life.”
Pursuant to the Prison Litigation Reform Act (“PLRA”), 42 U.S.C. §1997e(a), “[n]o action shall be brought with respect to prison conditions under §1983 of this title, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.”
The Court held the PLRA’s exhaustion requirement applies to all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong.
Thus, pursuant to the PLRA, exhaustion of all administrative remedies is “mandatory” and a “prerequisite to a suit.”
This means that a plaintiff must exhaust all available remedies prior to commencing an action in federal court, even if the available remedies are not “plain, speedy and effective” or do “not meet federal standards.” Administrative law requires “proper exhaustion” of administrative remedies, which means using all steps that the agency holds out, and doing so properly. Proper exhaustion also includes compliance with deadlines and other critical procedural rules.
Case #10: Ross v. Blake, 136 S.Ct. 1850 (2016)
There are some “circumstances in which an administrative remedy, although officially on the books, is not capable of use to obtain relief.”
This means that “an inmate is required to exhaust those, but only those, grievance procedures that are capable of use to obtain some relief for the action complained of.”
The Prison Litigation Reform Act (“PLRA”) bars prisoners from bringing any action “with respect to prison conditions under §1983… until such administrative remedies as are available are exhausted.” 42 U.S.C. §1997e(a).
PLRA language is “mandatory,” and “suggests no limits on an inmate’s obligation to exhaust,” provided that remedies are indeed “available” to the prisoner.
If administrative remedies are in fact unavailable, then an inmate’s failure to exhaust may be excused. The Court held that an administrative procedure will be treated as “unavailable” for purposes of exhaustion in at least three instances: 1) when “it operates as a simple dead end with officers unable or consistently unwilling to provide any relief to aggrieved inmates” 2) when it is “so opaque that it becomes, practically speaking, incapable of use” and, 3) when “prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation.”
Bonus Prisoner Rights Supreme Court Case
Case #11: Heck v. Humphrey, 114 S.Ct. 2364 (1994)
When “a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence,” the Court held 42 U.S.C. §1983 is not an available remedy. “But, if… the plaintiff’s action, even if successful, will not demonstrate the invalidity of [his conviction or sentence], the action should be allowed to proceed.”
Wolff makes clear that §1983 remains available for procedural challenges where success in the action would not result in an immediate or speedier release for the prisoner. Conversely, Heck specifies that a prisoner cannot use §1983 to obtain damages where success would necessarily imply the unlawfulness of a (not previously invalidated) conviction or sentence.
“In order to recover damages for allegedly unconstitutional conviction or imprisonment, a civil rights plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus.”
Any conviction or sentence imposed after, or as a result of, a constitutional violation must be vacated before initiating a §1983 lawsuit. For example, a convicted defendant could not sue police officers for an invalid search warrant without first having the ensuing conviction vacated.
This case’s holding is frequently overlooked by prisoners and worthy to be included as a bonus in my top ten list.
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