Rufo v. Inmates of Suffolk County Jail

In 1971, Suffolk County Jail inmates (plaintiffs) sued multiple government officials (defendants), claiming detainees awaiting trial were held under unconstitutional conditions due to overcrowding. The court entered an injunction, but problems continued. The appellate court ordered the jail closed absent a plan to make a constitutionally adequate facility. Officials submitted an architectural plan for a new jail with 309 single-occupant cells based on a projected decline in inmate population. The court described the plan as “constitutionally adequate and constitutionally required” and incorporated it into a consent decree. Shortly thereafter, the Supreme Court upheld double-celling. Meanwhile, inmate populations increased before construction began. In 1985, the court modified the decree to allow capacity increases but not double-celling, ultimately increasing the plan to 453 cells. County sheriff Robert Rufo requested a modification to allow double-bunking in 197 cells, increasing capacity to 610 inmates. The district court refused modification absent “grievous wrong evoked by new and unforeseen conditions” as described in United States v. Swift & Co., 286 U.S. 106 (1932), reasoning that the increased inmate population was neither new nor unforeseen, that allowing double-celling did not change any interpretation of the law on which the consent decree was based, and that single-celling was essential. The new jail opened shortly afterward with 453 single-occupancy cells. After the appellate court affirmed, the Supreme Court granted review.