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NCJ Number: NCJ 095530     Find in a Library
Title: Constitutional Law - Eighth Amendment - Double Celling of Long Term Inmates - Cruel and Unusual Confinement - Rhodes vs Chapman
Journal: New York Law School Law Review  Volume:28  Issue:2  Dated:(1983)  Pages:519-539
Author(s): T G Ronan
Date Published: 1983
Page Count: 21
Language: English
Country: United States of America
Annotation: The U.S. Supreme Court decision in Rhodes v. Chapman (1981), which overturned the lower courts' decision by finding that double celling in an Ohio prison did not constitute cruel and unusual punishment, is not a retreat from the Court's activist role, but a reassertion of its position as the ultimate arbiter of the effect of penological policies on the imprisoned.
Abstract: In Rhodes v. Chapman, the inmates at the South Ohio Correctional Facility instituted a class action challenging the constitutionality of double celling. The district court found that the totality of circumstances at the facility was generally favorable, but based its finding of unconstitutional infringement on five factors: the inmates' long sentences, overcrowding, size of shared cells, amount of time spent by inmates in cells, and the prison officials' attitude that the practice was a permanent solution to overcrowding. The Supreme Court reversed the district and circuit courts' holding. Historically, the Court's interpretation of eighth amendment standards has developed to meet the 'evolving standards of decency that mark the progress of a maturing society,' and there are no rigid guidelines for courts in eighth amendment analyses. The Federal courts first evaluate the negative impact of prison conditions on inmates' physical, mental, or emotional health and lately have found poor and intolerable living conditions to constitute cruel and unusual punishment. Although double celling as a method of coping with prison overcrowding has become a recurrent subject of litigation, the practice has not been held per se to be unconstitutional. When double celling, however, contributes to a totality of circumstances that result in constitutional deprivation, it may be barred by the eighth amendment. The majority of the U.S. Supreme Court that reversed the Chapman decision held that the Court that reversed the Chapman decision held that the inmate harm from double celling was a natural consequence of incarceration and neither cruel nor unusual in its purpose or effect. Concurring and dissenting opinions in Chapman agreed that conditions should be evaluated in accordance with the evolving standards-of-decency and the totality-of-circumstances doctrines, but disagreed over what level of harm triggered eighth amendment proscriptions. The paper includes 147 footnotes.
Index Term(s): Inmate grievances ; Cruel and unusual punishment ; State correctional facilities ; Inmate lawsuits ; Prison overcrowding ; US Supreme Court decisions
   
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