## Facts

- Incarcerated individuals at the Southern Ohio Correctional Facility (SOCF), a modern maximum-security prison, brought a class action under 42 U.S.C. § 1983 against Ohio prison officials.
- The challenge focused on “double celling”: housing two inmates in a cell originally designed for one.
- SOCF housed approximately 38% more inmates than its design capacity.
- Double-celled inmates shared a cell space of roughly 63 square feet.
- The district court found SOCF’s overall physical and programmatic conditions generally favorable (including modern facilities).
- Despite those findings, the district court held double celling unconstitutional based on: long-term sentences, overcrowding relative to design capacity, expert space recommendations, asserted time spent in cells, and the long-term nature of the policy.
- The court of appeals affirmed.

## Issues

1. Whether double celling at a modern maximum-security prison, on this record, constitutes cruel and unusual punishment prohibited by the Eighth Amendment as applied to the States through the Fourteenth Amendment.

## Decision

- The Supreme Court reversed, holding that double celling at SOCF did not violate the Eighth and Fourteenth Amendments.
- The Court stated the Eighth Amendment does not constitutionalize particular prison design standards or per-inmate square footage.
- The Court found the lower court’s key factors, alone or in combination, insufficient without evidence of serious deprivation, wanton infliction of pain, or gross disproportionality.
- The Court emphasized the absence of proof that double celling caused serious physical or psychological harm, materially increased violence, or denied basic needs such as food, medical care, or sanitation.
- The Court cautioned that prison administration decisions are primarily for legislatures and prison officials, and courts should not substitute their judgments absent a constitutional violation.
- Justice Marshall dissented; other Justices concurred in the judgment, warning that more severe or different conditions could change the analysis.

## Legal Principles

- Conditions of confinement violate the Eighth Amendment only if they involve the wanton and unnecessary infliction of pain or are grossly disproportionate to the severity of the crime.
- Restrictive or harsh conditions may be constitutionally permissible if consistent with contemporary standards and if they do not impose serious deprivations of basic human needs.
- Overcrowding, deviation from recommended space standards, or exceeding “design capacity,” without demonstrated serious harm or deprivation, does not by itself establish cruel and unusual punishment.
- Courts should give substantial deference to legislative and administrative judgments in prison management, intervening only when conditions cross constitutional limits.

## Conclusion

The Court held that double celling in an otherwise modern, adequately run prison does not amount to cruel and unusual punishment absent objective evidence of serious deprivation or the wanton and unnecessary infliction of pain.


Rhodes v. Chapman, 452 U.S. 337 (1981)