Plata v. Brown

A district court’s order is consistent with the Prison Litigation Reform Act if it is “a sensible scheduling order designed to provide the court and Plaintiffs with adequate notice of the evidence the State intends to rely upon in a motion to terminate.”

In order to place the control of prisons back into the hands of state and local officials, Congress enacted the Prison Litigation Reform Act (“PLRA”). Since 2006, California prisons have been releasing prisoners within the strictures of the PLRA and have been operating under a receivership to comply with the consent decrees. Under the PLRA, “a defendant involved in prison litigation may move to terminate any prospective relief after the date of the court approved relief.” The appeal before the panel involved the termination of certain decrees within the PLRA. In 2001, Plaintiffs filed a class action suit alleging that the prison healthcare system violated the Eighth Amendment and the American Disabilities Act. The parties entered into two consent decrees, the first consent decree “required the State to implement various remedial measures to ensure the provision of constitutionally adequate healthcare in California prisons.” When little to no progress was made, the district court then issued an order requiring the State to show cause as to why it should not be held in contempt. The district court found that the State was noncompliant, so in 2006, the district court appointed a receiver. In 2012, the district court ordered the parties to meet with one another and discuss post-receivership planning. In 2013, the district court directed the State to answer whether it intended to file an answer relating to the class action that the prisoners brought forth in California. The State responded that it would move to terminate the relief. The Ninth Circuit held that the district court’s order was “a sensible scheduling order designed to provide the court and Plaintiffs with adequate notice of the evidence the State intends to rely upon in a motion to terminate,” and was consistent with the provisions of the statute originally enacted by Congress. DENIED.