Mitchell v. Cate

2:08–cv–01196–TLN–EFB (2016)

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Mitchell v. Cate

United States District Court for the Eastern District of California
2:08–cv–01196–TLN–EFB (2016)

Facts

Robert Mitchell (plaintiff) was a Hispanic prisoner incarcerated in a California prison. Mitchell sued the California Department of Corrections and Rehabilitation (CDCR) (defendant) in federal district court. Mitchell alleged the CDCR had a policy that if a lockdown was required for a prisoner of one race, all prisoners of that race were locked down. A lockdown involved restricting the prisoners’ movements within the prison, such as confining them to a cell. Lockdowns could last for hours or more than a year. Mitchell alleged that this practice violated his equal-protection and due-process rights under the Fourteenth Amendment. The district court certified the case as a class action and denied CDCR’s motion for summary judgment on several of the class claims. The parties then worked out a settlement agreement. The CDCR agreed to change its race-based lockdown policy and, instead, to only lock down either (1) all prisoners in a geographic area if needed for security purposes or (2) specific prisoners based on an individualized threat assessment, using an agreed-upon point system. Further, under the settlement agreement, if any lockdown lasted more than 14 days, the CDCR agreed that a warden would create a plan to allow the locked-down inmates access to outdoor activities as part of the lockdown. The parties asked the court to approve the settlement.

Rule of Law

Issue

Holding and Reasoning (Nunley, J.)

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