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Rationale behind the Supreme Court’s decision
The Supreme Court case that is going to be discussed in this paper is 2011 Brown, Governor of California v. Plata (No. 09–1233). This case ended with the Supreme Court affirming the appropriateness of the legal ruling (passed by the District Court for the Eastern and Northern Districts of California) that the State of California was to reduce prison-population to account for no higher than 137.5% of the correctional facilities’ combined holding capacity.
The Court’s decision, in this respect, reflected the willingness of the majority of Judges to confirm that the provisions of the Eighth Amendment to the U.S. Constitution do apply to prisoners in California, as much as they apply to the rest of the citizens. As Rogan noted: “In Plata the Supreme Court held, by a majority of 5:4, that the population limit mandated by the three-judge court was necessary to remedy the violation of the constitutional rights of prisoners under the Eighth Amendment’s prohibition on cruel and unusual punishments” (223). The actual logic (voiced by Judge Kennedy), as to why the Supreme Court decided to rule against the State in the Brown v. Plata case, had to do with the following case-related consideration:
It has been proven beyond any reasonable doubt that whereas, as of 2011, the maximal holding capacity of State prisons accounted for 80.000, California’s population of prison-inmates in that year has reached 160.000. This, in turn, resulted in overcrowding – hence, making it increasingly impossible for the inmates to lead more or less dignified lifestyles. According to how the majority of Judges saw it: “Overcrowding… created unsanitary and unsafe conditions that make progress in the provision of care difﬁcult or impossible to achieve” (“Opinion of the Court” 3).
However, the described state of affairs stood in a striking contradiction to the main provisions of both: the Constitution’s Eight Amendment and the UN Universal Declaration of Human Rights, which specify the sheer inappropriateness of subjecting convicts to any ‘cruel and unusual’ punishment: “Prisoners may be deprived of rights that are fundamental to liberty. Yet… prisoners retain the essence of human dignity inherent in all persons.
Respect for that dignity animates the Eighth Amendment prohibition against cruel and unusual punishment” (“Opinion of the Court” 12). To prove further the legal soundness of the Court’s decision in the case Brown vs. Plata, Judge Kennedy referred to the precedent-establishing case Atkins v. Virginia, during the course of which it was determined that the Eighth Amendment’s subject matter is indeed concerned with the protection of one’s dignity as a citizen and a human being.
The non-unanimous nature of the mentioned decision implies that some Judges did not agree with it. Judge Scalia and Judge Alito opted to formulate some of their dissenting opinions, as to the dubious appropriateness of the manner in which the Supreme Court handled the Brown vs. Plata case. The main of them are as follows:
- The allegation that prisoners in California suffer from being subjected to ‘cruel and unusual’ punishment is essentially concerned with the thoroughly logical assumption that overcrowding results in preventing many of them from being able to have access to the timely and adequately delivered healthcare services. This assumption, however, does not take into consideration the fact that most of the would-be released 46.000 prisoners (due to the Court’s decision) do not have any particularly acute health problems. As Judge Scalia pointed out: “Most of them (prisoners) will not be prisoners with medical conditions or severe mental illness; and many will undoubtedly be fine physical specimens who have developed intimidating muscles pumping iron in the prison gym” (“Scalia J Dissenting” 5). Thus, the mentioned problem of prison-overcrowding should be seen reflective of the overall lack of functional efficiency, on the part of the State, rather than something that represents a legitimate legal issue.
- By having ruled in favor of the plaintiff (Plata), the Supreme Court acted in the essentially anti-Constitutional manner. After all, its decision on the Brown v. Plata case can be interpreted as such that exposes the Court’s willingness to embrace more judiciary powers than allowed by the Constitution. According to the dissenting view of Judge Alito: “The Constitution does not give federal judges the authority to run state penal systems… while the Eighth Amendment placed an important restraint on state authority, it was a limited restraint” (“Alito J Dissenting” 7). As a result, there will be certain doubts about whether the Court’s decision in question can be considered legally binding.
- The Supreme Court’s decision is rather inconsistent with the Prison Litigation Reform Act (PLRA), in the sense of not taking into consideration the Act’s main provision. According to it, no adjustments should be applied to the functioning of the country’s legal system, for as long as there is a good reason to believe that it will result in the nationwide rise of crime. As Judge Alito argued: “Nothing in the PLRA suggests that public safety may be sacrificed in order to implement an immediate remedy rather than a less dangerous one that requires a more extended but reasonable period of time” (“Alito J Dissenting” 10). Quite understandably, this implies that the Supreme Court’s decision in the Brown v. Plata case can hardly be deemed very beneficial to the overall well-being of American society – something that illegitimates it even further.
To understand better the discursive significance of the discussed case, we can refer to the well-established fact that there is a negative correlation between the varying extent of a particular case’s affiliation with the matters of politics/ideology, on one hand, and the Supreme Court’s likelihood to come up with the unanimous (either positive or negative) decision, in regards to what should be the actual outcome of this case.
As Lee, Landes, and Posner aptly observed: “The ideological stakes are small in cases that are candidates for being decided unanimously, so even slight dissent aversion will generate a unanimous decision in cases in which the ideological stakes are low” (702). Therefore, there is indeed nothing too surprising about the fact that in the case Brown v. Plata a few Judges decided to express their dissent with the legal rationale, behind the Court’s final ruling. After all, there can be only a few doubts as to the case’s strongly defined ideological/political sounding.
The main reason why it appears to be the case is that by having taken the plaintiff’s side, the Supreme Court declared its subtle intention to reassess the validity of some of this country’s foremost Constitutional principles. There is, however, even more to it – although it does this implicitly, the Court’s decision implies that the State authorities must prioritize the provisions of the international law while dealing with the so-called ‘civil right’ issues.
This simply could not be otherwise – many provisions of the Constitution’s Eighth Amendment are essentially the same with those of the U.N. Declaration of Human Rights. What it means is that while in the process of deliberating the case, most Judges could not help perceiving its legal aspects through the lenses of what happened to be their political affiliation – hence, the consequential dissent.
Even though, as it was shown earlier, the case Brown vs. Plata is rather controversial/multidimensional, the Supreme Court’s decision to uphold the ruling of the District Court of California is best referred to as thoroughly appropriate. There are two reasons to believe that this is indeed the case:
- The Supreme Court’s decision is discursively sound, in the sense of being consistent with the post-modern outlook on should be considered the main purpose of incarcerating citizens – to set the latter on the path of physical/mental rehabilitation, rather than to punish convicts, as something that has the value of a ‘thing in itself’. In this sense, the discussed decision does provide some additional legitimacy to the idea that the actual function of correctional institutions in America should undergo a qualitative transformation.
- The Supreme Court’s decision reaffirms the responsibility of the State for ensuring the reasonable well-being of imprisoned convicts – something that should slow down the process of the penal system in every individual State becoming increasingly commercialized/privatized, which in turn often results in the overcrowding of jails. Thus, even though the concerned decision does seem to undermine the sovereign authority of the State, the resulting effect is opposite – because of the case’s outcome, the State has been once again reconfirmed to be in charge of managing the qualitative dynamics within the society.
Alito J Dissenting. Brown, Governor of California v. Plata. 563 U. S. (2011). No. 09–1233. Supreme Court of the United States. Web.
Lee, Epstein, Landes, William and Richard Posner. “Are Even Unanimous Decisions in The United States Supreme Court Ideological?.” Northwestern University Law Review 106.2 (2012): 699-713.
Opinion of the Court. Brown, Governor of California v. Plata. 563 U. S. (2011). No. 09–1233. Supreme Court of the United States. Web.
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Rogan, Mary. “Brown, Governor of California v. Plata.” Modern Law Review 75.2 (2012): 261-274
Scalia J Dissenting. Brown, Governor of California v. Plata. 563 U. S. (2011). No. 09–1233. Supreme Court of the United States. Web.