## Facts

- Inmates at Pelican Bay State Prison brought a class action against California corrections officials challenging conditions and practices at the prison, including the Security Housing Unit (SHU).
- Pelican Bay operated as a supermaximum facility; the SHU imposed highly restrictive confinement designed to minimize social contact and environmental stimulation.
- SHU prisoners typically spent about 22.5 hours per day in small cells with minimal views, little human interaction, limited programming, and non-contact visitation.
- Prisoners could be assigned to the SHU for serious discipline, perceived violence risk, or validated prison-gang affiliation; gang-based SHU terms could be indeterminate.
- Plaintiffs alleged unconstitutional practices including staff excessive force, deficient medical care, deficient mental-health care, harmful SHU isolation (especially for mentally ill or vulnerable prisoners), unsafe cell-assignment practices, and unconstitutional gang-segregation procedures.
- After an extensive bench trial, the court issued detailed findings and orders addressing force, health care, SHU confinement, housing, and gang-related segregation.

## Issues

1. Whether staff use of force at Pelican Bay involved unconstitutional excessive force under the Eighth Amendment.
2. Whether systemic deficiencies in medical and mental-health care constituted deliberate indifference to serious needs in violation of the Eighth Amendment.
3. Whether SHU conditions—extreme isolation and sensory deprivation—violated the Eighth Amendment, either facially or as applied to particular prisoner groups.
4. Whether cell-assignment practices and gang-validation/segregation practices violated the Eighth Amendment and, as to gang-based SHU placement, due process requirements.

## Decision

- The court found Eighth Amendment violations in multiple areas, including a pattern of excessive force and constitutionally inadequate medical and mental-health care.
- The court held SHU conditions were not per se unconstitutional for all prisoners, but were unconstitutional as applied to prisoners with serious mental illness and certain psychologically vulnerable prisoners because the risk of severe harm was excessive.
- The court found certain housing practices (including some double-celling/compatibility decisions) exposed prisoners to substantial risk of serious harm and were constitutionally deficient.
- The court upheld the state’s general interest in gang control but required changes to gang-based SHU practices to reduce erroneous or unjustified long-term confinement and to ensure meaningful review.
- The court granted broad injunctive relief requiring reforms to use-of-force policies and oversight, improvements in medical and mental-health services, limits on SHU placement/retention for seriously mentally ill or vulnerable prisoners, and changes to housing and gang-segregation procedures.

## Legal Principles

- Eighth Amendment conditions-of-confinement claims require an objectively serious deprivation or risk of harm and a subjective showing that officials acted with deliberate indifference or inflicted wanton pain.
- Excessive force violates the Eighth Amendment when force is used maliciously or sadistically for punishment or intimidation rather than for legitimate security needs.
- Systemic failures in medical or mental-health care can constitute deliberate indifference where deficiencies create a substantial risk of serious harm and officials fail to take reasonable corrective measures.
- Extreme isolation and sensory deprivation may be constitutionally permissible for some prisoners but can violate the Eighth Amendment when applied to prisoners whose mental illness or special vulnerabilities make serious psychiatric harm a foreseeable consequence.
- Prison officials violate the Eighth Amendment when they knowingly expose prisoners to a substantial risk of serious harm from cell-assignment practices without adequate protective measures.
- Gang-based segregation into harsh, potentially indeterminate SHU confinement must include basic procedural protections such as notice and periodic, meaningful review sufficient to reduce arbitrary or erroneous placement.

## Conclusion

The court held that several Pelican Bay practices violated the Eighth Amendment, ordered extensive injunctive reforms, and drew a key constitutional line by restricting SHU confinement for prisoners with serious mental illness or heightened psychological vulnerability while declining to deem SHU conditions categorically unconstitutional for all prisoners.


Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995)