Ninth Circuit Terminates Idaho Prison Conditions Lawsuit After 40 Years of Litigation
by David M. Reutter
On March 22, 2022, the U.S. Court of Appeals for the Ninth Circuit affirmed termination of all prospective relief in a long-running class action alleging unconstitutional conditions at the Idaho State Correctional Institution (ISCI).
The Court’s opinion ended a 1981 lawsuit filed by prisoner Walter Balla, under which a number of similar cases were later consolidated by the federal court for the District of Idaho. In 1984, that court concluded that conditions of confinement at ISCI violated Plaintiffs’ Eighth and Fourteenth Amendment rights. It granted injunctive relief in nine orders related mostly to medical care and physical safety, plus one requiring rehabilitative programming for sex offenders. See: Balla v. Idaho State Bd. of Corr., 595 F.Supp 1558 (D. Idaho 1984).
Five of those orders were then terminated by stipulation. But when the population at ISCI increased, the district court found unconstitutional overcrowding amounting to unnecessary and wanton infliction of pain. As a result, more than ten additional orders were issued setting population caps, staffing requirements, and other restrictions, as well as a mandate that population caps could be increased only after structural changes or redesign. See: Balla v. Bd. of Corr., 656 F. Supp. 1108 (D. Idaho 1987).
Meanwhile, Plaintiffs challenged the sufficiency of the district court’s plans, but they were affirmed by the Ninth Circuit in a 1989 ruling, which also reversed the order to provide rehabilitative programming because there is no “constitutional right to rehabilitation.” See: Balla v. Idaho State Bd. of Corr., 869 F.2d 461 (9th Cir. 1989).
In 2005, the Court recalled, “the district court found ‘conditions that [were] worse, both as to overall inmate population and plumbing problems, than when the original injunctive orders were put in place.’” See: Balla v. Idaho Bd. of Corr., 2005 U.S. Dist. LEXIS 51482 (D. Idaho), clarified on denial of reconsideration at 2005 U.S. Dist. LEXIS 38804 (D. Idaho).
That led to appointment in 2011 of a special master, who investigated prison officials’ compliance and found they were deliberately indifferent to the medical and mental healthcare needs of prisoners. After mediation, the parties agreed in 2012 to a settlement outlining procedures to modify the compliance plans to allow ISCI to seek certification by the National Commission on Correctional Health Care (NCCHC). If that certification were granted, the parties would voluntarily terminate the court orders. [See PLN, Feb. 2013, p. 40.]
After adopting a modified compliance plan in 2014, the district court entered sanctions for Defendants in 2015 because they falsified and manipulated medical records, misleading the special master. It extended the monitoring period and struck the automatic termination of some terms after NCCHC certification. [See: PLN, Nov. 2016, p.44.]
Then in September 2017, the district court found Defendants in contempt for past failure to follow the 2014 order. [See: PLN, June 2018, p.51.]
Defendants moved to terminate all prospective relief pursuant to 18 U.S.C. § 3626(b). The Class countered that the failure to treat prisoners with Hepatitis C was a current and ongoing violation. But the district court wasn’t interested in hearing an issue never raised before in the litigation. Moreover, it said that Hepatitis C was being addressed in a separate class action. See: Turkey v. Atencio, USDC (D. Idaho), Case No. 1:18-cv-00001.
After an 11-day evidentiary hearing, the district court found no ongoing constitutional violations and granted Defendants’ motion to terminate. The Class appealed.
Taking up the case again, the Ninth Circuit addressed the Hepatitis C claim first, finding it was not at issue in this long-running class action. Rather, it said, the Class was concerned with the general provision of medical care, and there were no previous findings specifically related to Hepatitis C. The Court also agreed there was no evidence that conditions at ISCI’s Medical Annex rose to the level of an Eighth Amendment violation. In fact, the record supported the district court’s finding that Defendants complied with staffing requirements for medium-custody units. Moreover, the parties agreed that Defendants complied with required population caps. The Class’ attempt to challenge 2005 orders terminating earlier population caps was also dismissed as untimely.
Thus the Court found that “Defendants met their burden of showing there was no ongoing constitutional violation,” and the district court’s order was affirmed. Plaintiffs were represented by attorneys from the Stoel Rives firm in Boise, which has provided Plaintiffs’ counsel in this case since recruited by the district court before its 2005 decision in the case. See: Balla v. Idaho, 29 F.4th 1019 (9th Cir. 2022).
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Related legal cases
Balla v. Idaho
| Year | 2022 |
|---|---|
| Cite | 29 F.4th 1019 (9th Cir. 2022). |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
Balla v. Idaho Bd. of Corrections
| Year | 2005 |
|---|---|
| Cite | 2005 WL 3412806 |
| Level | District Court |
| Conclusion | Bench Verdict |
| Attorney Fees | 50054 |
| Damages | 0 |
| Injunction Status | Granted |
Balla v. Idaho State Bd. of Corr.
| Year | 1989 |
|---|---|
| Cite | 869 F.2d 461 (9th Cir. 1989) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Appeals Court Edition | F.2d |
Balla v. Idaho Board of Correction
| Year | 1987 |
|---|---|
| Cite | 656 F.Supp. 1108 (D. Id. 1987) |
| Level | District Court |
| Injunction Status | Granted |
Balla v. Idaho State Bd. of Corr.
| Year | 1984 |
|---|---|
| Cite | 595 F.Supp 1558 (D. Idaho 1984) |
| Level | District Court |
| Conclusion | Bench Verdict |
| District Court Edition | F.Supp. |