## Facts

- Arkansas prisoners challenged conditions in the state prison system, focusing on punitive isolation, as violating the Eighth and Fourteenth Amendments.
- Punitive isolation involved crowded, windowless, unsanitary cells, often without adequate sleeping arrangements, and could be imposed for indeterminate periods.
- Prisoners in isolation could be subjected to a nutritionally inadequate “grue” diet for extended periods.
- After prolonged prison-conditions litigation, the federal district court found continuing constitutional violations and entered detailed remedial orders.
- The district court’s remedy included limiting punitive-isolation sentences to a maximum of 30 days, restricting the number of inmates per cell, requiring bunks, and ending long-term use of the “grue” diet.
- The district court awarded attorney’s fees against prison officials, finding bad-faith failure to cure previously identified unconstitutional conditions.
- The court of appeals largely affirmed the injunction and approved attorney’s fees, including additional fees for appellate work.
- State correctional officials sought Supreme Court review of the 30-day cap and the attorney’s-fees awards payable from correctional-department funds.

## Issues

1. Whether a federal district court exceeded its equitable remedial authority by imposing a 30-day maximum on punitive isolation to remedy Eighth Amendment violations in state prisons.
2. Whether attorney’s fees ordered against state prison officials and payable from state correctional funds, based on a bad-faith finding, were barred by the Eleventh Amendment.
3. Whether the Civil Rights Attorney’s Fees Awards Act of 1976 authorized additional attorney’s fees in a § 1983 prison-conditions case despite state sovereign-immunity objections.

## Decision

- The Supreme Court affirmed the challenged parts of the remedial order and the attorney’s-fees awards.
- The Court held the 30-day cap on punitive isolation was a permissible component of a comprehensive remedy for systemic Eighth Amendment violations.
- The Court held the Eleventh Amendment did not bar a fee award payable from correctional-department funds where the award was grounded in officials’ bad faith and operated like a sanction to enforce compliance with prospective relief.
- The Court held the 1976 Fees Act authorized reasonable attorney’s fees “as part of the costs” in § 1983 actions and that Congress validly permitted such costs awards against states; the additional appellate fee award was therefore proper.

## Legal Principles

- Eighth Amendment compliance in confinement cases may require evaluating the combined effect of conditions and the duration of exposure; conditions tolerable briefly can become unconstitutional when prolonged.
- Federal courts may order detailed, structural injunctive relief when necessary to correct and prevent recurrence of systemic constitutional violations in state institutions.
- Attorney’s fees may be awarded against state officials based on bad-faith conduct in litigation or noncompliance, and such awards may be treated as enforcement measures tied to prospective injunctive relief rather than barred retroactive damages.
- Under the Civil Rights Attorney’s Fees Awards Act of 1976, courts may award reasonable attorney’s fees to prevailing parties in § 1983 litigation as part of taxable costs, and state sovereign-immunity objections do not bar such costs awards.

## Conclusion

The Court sustained broad equitable relief to cure unconstitutional prison conditions, including a 30-day ceiling on punitive isolation based on the interaction of harsh conditions and time, and it affirmed attorney’s-fees awards against state prison officials both as a bad-faith enforcement measure and under Congress’s fee-shifting authorization for civil-rights cases.


Hutto v. Finney, 437 U.S. 678 (1978)