## Facts

- Inmates at the New Hampshire State Prison (NHSP) brought a class action under 42 U.S.C. § 1983 on behalf of all current and future NHSP prisoners.
- The suit began as a challenge to an “emergency lockup” and prison-wide “shakedown,” alleging unconstitutional lockdown, searches, property confiscation, and restrictions on visits.
- After counsel was appointed, the litigation expanded into a comprehensive challenge to conditions of confinement and prison programs, including medical and mental health care, work and education opportunities, classification, staffing, fire safety, visitation, and mail.
- The case proceeded against the warden, prison physician, and members of the prison board of trustees in their official capacities.
- The court certified a Rule 23(b)(2) class and held a merits proceeding addressing the cumulative effect of prison conditions and institutional policies.

## Issues

1. Whether the totality of conditions and program deficiencies at NHSP constituted cruel and unusual punishment under the Eighth Amendment.
2. Whether deficiencies in medical and mental health services at NHSP failed to meet constitutional minimums.
3. Whether certain prison administrative policies (including transfer restrictions requiring approval by a judge or the governor) were unconstitutional because they impeded necessary correctional management and remediation.
4. Whether visitation, mail, classification, and related practices unlawfully burdened prisoners’ constitutional protections under the Fourteenth Amendment and other applicable provisions.

## Decision

- The court found significant constitutional violations and entered broad injunctive relief.
- The court held that, even without identifying a single isolated condition that was independently “shocking,” the cumulative impact of conditions and the lack of adequate programs violated the Eighth Amendment because they made prisoner degeneration probable and reform unlikely.
- The court found constitutionally inadequate medical and mental health care and ordered remedial measures to correct systemic deficiencies.
- The court declared unconstitutional a state transfer-approval requirement that conditioned inmate transfers on approval by a superior court judge or the governor.
- The court ordered corrective action for serious safety problems, including fire hazards, and directed changes affecting staffing, classification practices, vocational/educational opportunities, visitation, and mail.
- The court appointed a special master to supervise implementation of the remedial orders.

## Legal Principles

- Eighth Amendment liability for prison conditions may be established by the totality of conditions; multiple deficiencies may combine to produce unconstitutional confinement even if no single condition is independently extreme.
- Conditions of confinement violate the Eighth Amendment when their cumulative effect threatens inmates’ health and safety and creates an environment where degeneration is probable and reform unlikely.
- Constitutionally adequate medical and mental health care is a required component of lawful confinement; systemic inadequacies can support injunctive relief.
- Courts may invalidate correctional policies that obstruct prison administrators’ ability to address unconstitutional conditions, including transfer restrictions that impede appropriate placement or remediation.
- In institutional reform litigation under § 1983, federal courts may issue detailed injunctive relief and use oversight mechanisms (such as a special master) to secure compliance with constitutional standards.

## Conclusion

The court concluded that NHSP’s overall conditions and program failures, viewed cumulatively, amounted to cruel and unusual punishment and required extensive court-ordered reforms, including improvements to medical and mental health care, safety measures, and changes to institutional policies that hindered constitutional compliance.


Laaman v. Helgemoe, 437 F. Supp. 269 (D.N.H. 1977)