Prison-overcrowding cases typically focus on whether overcrowding per se or conditions derived from overcrowding violate the constitutional prohibition against cruel and unusual punishment. The courts have difficulty in interpreting this standard because it rests on changing public views of humane treatment. In Bell v. Wolfish (1979) and Rhodes v. Chapman (1982), the U.S. Supreme Court reversed lower court decisions in holding that double-bunking in a single cell does not violate due process rights for pretrial detainees ('Bell') nor does it constitute cruel and unusual punishment for State inmates ('Rhodes'). A review of 21 relevant lower court cases since 'Rhodes' indicates that 61 percent of the cases were decided in favor of inmates on issues pertaining to prison overcrowding. District courts were significantly more sympathetic to overcrowding claims than appeal courts. Lower Federal courts split over the meaning of the following statement in the 'Rhodes' decision: Various conditions 'alone or in combination may deprive inmates of the minimal civilized measure of life's necessities.' The 'alone or in combination' was the controversial phrase. Factors in the 21 decisions that significantly affected the outcomes of prison-overcrowding litigation included the prison's age, amount of time in lockdown, the square footage below the 40-60 ft. per inmate, direct evidence of injury to health, violence attributable to crowding, and sexual inequality. 172 footnotes.