Lawson v. Cain

The Unnecessary Rigor Clause “is addressed specifically to the treatment of persons arrested, or confined in jail,” so “there can be no argument that rights under this guarantee are forfeited by conviction of crime or under lawful police custody.” Sterling, 290 Or at 619.

Defendant appealed a judgment granting habeas corpus relief to Plaintiff after an evidentiary hearing found that Snake River Correctional Institution (SRCI) failed to offer adequate protection for medically vulnerable inmmates against COVID-19. Defendant assigned error to the trial court's denial of his partial motion to dismiss, first arguing that the Unnecessary Rigor Clause (the Clause) in the Oregon Constitution does not apply to people who have been convicted of a crime and are serving a prison sentence. Defendant further argued that the court used the incorrect legal standard when deciding the inmate’s habeas corpus suit. Plaintiff argued that Sterling v. Cupp, 290 Or 611, 625 P2d 123 (1981) addressed each of Defendant's arguments and applies the Clause to prison conditions. The Unnecessary Rigor Clause “is addressed specifically to the treatment of persons arrested, or confined in jail,” so “there can be no argument that rights under this guarantee are forfeited by conviction of crime or under lawful police custody.” Sterling, 290 Or at 619. The Court explained that the Clause does not only apply to those serving post-conviction sentences; instead, it applies to persons arrested or confined, as a whole and provides an objective framework. Affirmed.