## Facts

- Alabama statutes required racial segregation of incarcerated persons in state prisons and in county and municipal jails.
- Multiple incarcerated Black plaintiffs filed a Rule 23 class action seeking declaratory and injunctive relief on behalf of similarly situated persons confined in Alabama penal facilities.
- Defendants included the Alabama Commissioner of Corrections, members of the Alabama Board of Corrections, and representative county sheriffs and municipal jail officials.
- Plaintiffs sought a declaration that Black citizens could not be segregated or otherwise subjected to race-based distinctions in confinement, and an injunction barring enforcement of segregation requirements.
- Alabama defended the statutory segregation scheme as necessary for prison discipline and security, asserting it helped maintain order and reduce violence.

## Issues

1. Whether statutes and practices mandating racial segregation in Alabama’s state, county, and municipal penal facilities violate the Equal Protection Clause of the Fourteenth Amendment.
2. Whether race-based segregation in confinement constitutes cruel and unusual punishment in violation of the Eighth Amendment (as applied to the states).
3. Whether generalized concerns about security and discipline can justify facially mandatory, permanent racial segregation in penal institutions.

## Decision

- The three-judge district court held unconstitutional Alabama statutes and practices requiring racial segregation in state prisons and local jails.
- The court rejected security and discipline rationales as insufficient to sustain statutes that mandated complete and permanent racial segregation across all penal facilities.
- The court acknowledged that, in isolated situations, officials might temporarily separate prisoners to address specific, time-limited security and discipline needs.
- The court granted declaratory and injunctive relief requiring desegregation across Alabama’s state, county, and municipal penal institutions.

## Legal Principles

- State-imposed racial segregation in prisons and jails violates the Equal Protection Clause.
- Prison security and discipline concerns do not justify statutes that, on their face, require complete and permanent racial segregation.
- Officials may consider security risks in particularized circumstances and for limited periods, but race-based separation cannot be imposed arbitrarily or as a blanket rule mandated by statute.

## Conclusion

The court invalidated Alabama’s statutory scheme of race-based segregation in prisons and jails, holding that categorical, permanent separation by race is unconstitutional under equal protection, while leaving open only narrow, temporary measures tied to specific security circumstances.


Washington v. Lee, 263 F. Supp. 327 (M.D. Ala. 1966)