NCJ Number
98823
Journal
Chicago-Kent Law Review Volume: 60 Dated: (1984) Pages: 291-316
Date Published
Unknown
Length
26 pages
Annotation
The constitutionality of prison conditions is considered within the context of the Seventh Circuit Court ruling in Smith v. Fairman, in which an inmate challenged confinement conditions at Illinois' Pontiac Corrections Center (PCC), alleging that housing two inmates in a single cell violated the eighth amendment prohibition against cruel and usual punishment.
Abstract
The court held that an examination of the totality of conditions at PCC revealed that overcrowding had not produced unconstitutional living conditions. The holding was based on a decline in institutional violence despite an upsurge in the prison population. The court concluded that while housing in two-man cells might be restrictive and harsh, it did not rise to the level of cruel and unusual punishment. It is suggested that, in this case, the court properly construed the issues of law and correctly emphasized the effects of double-celling. However, the court may have misconstrued the factual issues by giving too much weight to data produced by prison officials and not enough weight to the abstract studies cited by expert witnesses. In its quest to find credence in prison officials' data, the court often stretched to find explanations that would deny findings of the plaintiff's witnesses. The result was that some of the evidence was contradictory; conditions, such as the ventilation system and the presence of vermin, remain disputed. Implications of this decision for future litigation will be that courts will continue to emphasize the totality of conditions and the need for detailed and extensive data documenting the actual effects of long-term confinement in less than ideal conditions. Extensive footnotes are provided.