## Facts

- Two statewide prisoner class actions challenged California prison conditions: one alleged unconstitutional mental-health care; the other alleged unconstitutional medical care.
- Federal district courts found continuing Eighth Amendment violations in both systems and entered remedial injunctions; a special master monitored the mental-health case, and a receiver was appointed in the medical-care case after persistent noncompliance.
- California prisons operated at nearly double their design capacity, which court-appointed officials identified as a central structural barrier to providing minimally adequate care.
- Prisoners moved under the Prison Litigation Reform Act (PLRA) to convene a three-judge court to consider a “prisoner release order” (an order with the purpose or effect of reducing or limiting prison population).
- A three-judge district court, after extensive hearings, found overcrowding to be the primary cause of the constitutional violations and found that no other relief would remedy the violations.
- The three-judge court ordered California to reduce its prison population to 137.5% of design capacity within two years, leaving the State discretion over the means of compliance.
- State officials appealed directly to the U.S. Supreme Court.

## Issues

1. Whether the three-judge court’s population-reduction order satisfied the PLRA’s prerequisites and limits on prospective relief.
2. Whether the population cap was necessary to remedy ongoing Eighth Amendment violations in prison medical and mental-health care.
3. Whether the order exceeded constitutional limits on equitable relief in light of federalism and separation-of-powers concerns.

## Decision

- The Supreme Court affirmed in a 5–4 decision.
- The Court held that the population limit was necessary to remedy ongoing Eighth Amendment violations and was authorized by the PLRA.
- The Court concluded that the statutory requirements for a prisoner release order were satisfied, including findings—supported by clear and convincing evidence—that overcrowding was the primary cause of the violations and that no other relief would remedy them.
- The Court held the order was sufficiently tailored because it set a population target while allowing California to choose how to reach it and did not mandate the release of specific prisoners.
- Dissents argued the order was excessively broad, insufficiently tailored to individualized injuries, and posed unacceptable public-safety risks, and that the PLRA standards were not met.

## Legal Principles

- The Eighth Amendment prohibits prison conditions that deny minimally adequate medical and mental-health care and subject prisoners to serious risk of harm.
- Under the PLRA, prospective relief must be narrowly drawn, extend no further than necessary to correct a federal rights violation, and be the least intrusive means necessary.
- A three-judge court may issue a prisoner release order only after prior less intrusive relief has been tried, a reasonable time for compliance has passed without correction, and the court finds by clear and convincing evidence that overcrowding is the primary cause and no other relief will remedy the violation.
- A population cap may satisfy PLRA tailoring when it addresses the proven causal mechanism of constitutional violations and preserves substantial state discretion over implementation.
- Federal courts may order significant structural relief to end ongoing constitutional violations in prisons when supported by detailed factual findings and statutory compliance.

## Conclusion

The Court upheld a statewide population cap as a permissible PLRA remedy where chronic overcrowding was proven to be the primary cause of persistent Eighth Amendment failures in medical and mental-health care and where years of less intrusive remedies had not corrected the violations.


Brown v. Plata, 563 U.S. 493 (2011)