The Final Chapters of Ruiz V. Estelle. (Judicial News)
Reynolds, Carl, Corrections Today
In 1972, inmate David Ruiz filed a handwritten lawsuit against the Texas Department of Corrections (TDC), which was destined to become the most far-reaching prison conditions litigation in American history. It is likely that this epic case will come to complete closure on July 1; this article provides a retrospective of the "endgame."
The 1996 Prison Litigation Reform Act (PLRA) has been the pervasive theme of the past several years: Texas' efforts to invoke the act's consent decree section to end court jurisdiction, the district court's resistance to validity and mandate of the act, and the appellate court's enforcement of the act.
The original (1980) reported decision in Ruiz described the case's early stages: The civil action began in June 1972, when Ruiz filed suit against the TDC director, seeking declaratory and injunctive relief for alleged violations of his constitutional rights. During spring 1974, the civil action instituted by Ruiz was consolidated with the suits of seven other TDC inmates into a single civil action, styled Ruiz v. Estelle, 550 F.2d 238. Counsel was appointed to represent the indigent plaintiffs and the United States was ordered to appear in the case as amicus curiae (friend of the court). That December, the motion of the United States to intervene as a plaintiff was granted, and the addition of Texas Board of Corrections members as defendants also was allowed. A further order was entered that permitted the action to be maintained as a class action. Plaintiffs have challenged the following aspects of confinement in TDC prisons: crowding, security and supervision, health care, discipline, access to the courts a nd other general confinement conditions.
After decades of litigation and reform, reams of stipulations and decrees were reduced to a brief final judgment in 1992. Many issues were closed out and others were the subject of only global mandates, such as to maintain and enforce certain policies, e.g., use of force and to "employ sufficient trained security and non-security staff."
Persistent criticism of the continuation of any court oversight seemingly led Attorney General Dan Morales in March 1996 to file a motion to terminate the final judgment pursuant to Rule 60(b), Federal Rules of Civil Procedure, which is the generic provision for obtaining relief from a judgment that has been entered. One month later, Congress enacted PLRA, which affects prison conditions litigation by requiring: that the district court find that the existing prospective relief "remains necessary to correct a current and ongoing violation of [a] federal right and that the prospective relief is narrowly drawn and the least intrusive means to correct the violation"; immediate termination of prospective relief such as the final judgment; a prompt ruling on motions for relief, requiring an automatic stay of prospective relief unless the district court finds that relief remains necessary to correct a current or ongoing constitutional violation; and automatic termination of decrees on PLRA's second anniversary.
In September 1996, the attorney general filed a motion to terminate pursuant to PLRA, and later that month, federal Judge William Wayne Justice ruled that the automatic stay provision is unconstitutional; that section provided that a prison condition consent decree automatically was stayed after a defined period of time from the filing of the motion to terminate the decree. In July 1997, the attorney general withdrew the Rule 60(b) motion, seeking termination only under PLRA.
In August 1997, the 5th Circuit denied the state's attempt to mandamus (a writ commanding that a specific thing be done, issued by a higher court to a lower one) Justice to rule on the motion to terminate, and held that the district court was entitled to an updated record on the remaining substantive issues that were still relevant under the final judgment. …