## Facts

- A certified class of women incarcerated in the District of Columbia correctional system sued the District and correctional officials seeking declaratory and injunctive relief.
- The challenged conditions and programs involved three facilities: the Lorton Minimum Security Annex, the Correctional Treatment Facility (CTF), and the Central Detention Facility (Jail).
- After a multi-week bench trial, the district court found evidence of staff sexual harassment and abuse, inadequate obstetrical/gynecological care, inferior access to various programs relative to men, and deficiencies in general conditions and fire safety.
- The district court imposed a detailed injunction addressing sexual misconduct, medical care, programming, living conditions, and fire safety, and it also entertained negligence-based claims under D.C. Code § 24-442.
- The District appealed, disputing liability theories and arguing the injunction was overbroad; the Prison Litigation Reform Act (PLRA) became effective during the appeal.

## Issues

1. Whether the district court abused its discretion by exercising supplemental jurisdiction over negligence claims under D.C. Code § 24-442.
2. Whether Title IX and Fifth Amendment equal protection principles applied to program-parity comparisons between male and female prisoners on the record presented, including whether the compared groups were similarly situated.
3. Whether the proven conditions (including sexual abuse/harassment and inadequate obstetrical/gynecological care) amounted to Eighth Amendment violations and whether the injunction extended further than necessary to remedy any constitutional violations.
4. Whether, after enactment of the PLRA, the prospective relief required reconsideration to ensure statutory compliance.

## Decision

- Affirmed in part, reversed in part, and remanded.
- Reversed the exercise of supplemental jurisdiction over D.C. Code § 24-442 claims as an abuse of discretion.
- Reversed/vacated the Title IX and equal protection program-parity rulings because the male and female prisoners compared were not similarly situated on this record.
- Affirmed that certain conditions supported Eighth Amendment violations, particularly relating to sexual abuse/harassment and inadequate medical care for women.
- Held that portions of the injunction provided broader relief than necessary to cure Eighth Amendment violations and required narrowing.
- Remanded for the district court to assess whether additional portions of the order were inconsistent with the PLRA’s limits on prospective relief.

## Legal Principles

- A federal court may abuse its discretion by retaining supplemental jurisdiction over local-law negligence claims where those issues risk predominating over the federal claims and complicating adjudication.
- Title IX and equal protection challenges to disparities in prison programming require an appropriate comparator; absent a showing that the compared male and female prisoner populations are similarly situated, parity analysis is not applicable.
- Conditions of confinement violate the Eighth Amendment when they reflect unconstitutional treatment (including serious risks from sexual abuse and serious medical-care deficiencies); remedies must target the proven violations.
- Injunctive relief in institutional-reform prison litigation must be tailored to the scope of the constitutional violation and may not exceed what is necessary to correct it.
- Under the PLRA, prospective relief in prison-conditions cases must be narrowly drawn, extend no further than necessary to correct the violation, and employ the least intrusive means; courts must reassess existing decrees for compliance when required.

## Conclusion

The court upheld core Eighth Amendment liability findings tied to sexual abuse and inadequate women’s health care but rejected program-parity relief under Title IX and equal protection due to the lack of similarly situated comparators, reversed supplemental jurisdiction over local negligence claims, and remanded to narrow overbroad provisions and to ensure the injunction satisfied the PLRA’s constraints on prospective relief.


Women Prisoners of the D.C. Dep’t of Corr. v. District of Columbia, 93 F.3d 910 (D.C. Cir. 1996)