Griffin v. Gomez

A court will be found to abuse its discretion when issuing orders if it does not take subsequent, related developments into account or fails to apply appropriate authority.

Robert Lee Griffin has been in prison since 1970. During that time became a leader of the Aryan Brotherhood, a prison gang. Because of his active, and sometimes murderous, affiliation with this gang, he was moved to a security housing unit (“SHU”), which strictly confines prisoners. In 2006, the district court ordered that Griffin be released from SHU “immediately” because the harsh conditions of the SHU were unconstitutional and the length of his confinement in the SHU “vitiate[d] his ‘active’ gang participation.” However, at the time of this 2006 order, Griffin was no longer at the SHU because he had been moved to a federal prison on account of his role in a federal RICO case as a defendant. In 2007, he was found guilty in the RICO case. Griffin ultimately found his way back to the state prison system. Due to the state’s traditional investigation into a newly arrived prisoners’ gang affiliation, he was ordered back to the SHU. The Ninth Circuit decided the validity of two separate district court orders requiring that the 2006 order be upheld and Griffin be released from the SHU. The panel vacated these two orders for two independent reasons. First, both the orders were an abuse of discretion because the courts ignored subsequent developments to the 2006 order, such as informants claiming Griffin’s continued involvement in the Brotherhood. Second, in issuing the orders, the district courts failed to take proper Supreme Court authority into account. The panel cited four Supreme Court cases, which address the deference that courts must give to prison administrators’ judgments. Such ignorance went beyond the court’s responsibility to exercise restraint in its inherent authority. VACATED, REVERSED, AND REMANDED.