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Inmates of Sybil Brand Institute for Women v. County of Los Angeles
Citations: 130 Cal. App. 3d 89; 181 Cal. Rptr. 599; 1982 Cal. App. LEXIS 1497Docket: Civ. 61642
Court: California Court of Appeal; March 24, 1982; California; State Appellate Court
In the case **Inmates of Sybil Brand Institute for Women et al. v. County of Los Angeles et al.**, the plaintiffs, representing women incarcerated at Sybil Brand Institute, appealed a judgment regarding various constitutional violations. Key points of their appeal include: 1. The due process clause of the California Constitution requires strict scrutiny for significant restrictions on pretrial detainees' liberties beyond inherent detention limitations. 2. Substantial restraints imposed based on wealth must undergo strict scrutiny under the equal protection clause of the California Constitution. 3. Conditions at Sybil Brand Institute are inferior to those faced by male prisoners, constituting sex discrimination that necessitates careful examination. 4. The 14th Amendment's due process clause mandates that jail regulations affecting fundamental interests must align with legitimate jail administration needs. 5. The current prisoner processing procedures compromise the right to a fair trial and discriminate against pretrial detainees. 6. The absolute denial of contact visitation for female inmates is deemed unconstitutional. 7. Limited outdoor access for inmates is unconstitutional. 8. Telephone access for female inmates is inferior compared to male prisoners in other facilities, amounting to discrimination. 9. Defendants' disciplinary procedures fail to meet due process standards. 10. The procedures for placing inmates into administrative segregation do not conform to due process. Additionally, the County of Los Angeles cross-appealed regarding a $105,760 attorneys' fee award to the appellants, arguing that such fees should not cover efforts related to the fee application unless special circumstances justify it, claiming none exist in this case. The Sybil Brand Institute is identified as a facility with a capacity of 950 inmates, averaging 700 to 850 daily, with a mix of pretrial and sentenced individuals, and a high turnover rate. The facility features dormitories and cell blocks, with dormitories being noted as large and well-lit. Each housing area in the facility includes various amenities such as benches, tables, a television, and sanitary facilities. Inmates initiated a class action lawsuit against the Sheriff of Los Angeles County and other officials, contesting the legality of confinement conditions at the facility. The plaintiff class is divided into two subclasses: pretrial detainees and sentenced prisoners. The trial lasted approximately 14 days, during which numerous testimonies and exhibits were presented, and the trial judge inspected the facility. The trial court found certain practices unjustified by legitimate governmental interests and issued an injunction against them. However, it determined that some practices were justified due to modifications enacted by the sheriff prior to the judgment. Remaining challenged practices were either constitutional or deemed reasonable, including: denial of contact visits, dining room behavior rules, medical care, disciplinary procedures, limited male deputy involvement during disrobing of unstable inmates, court transportation procedures, use of control facilities, booking procedures, overcrowding issues, gender treatment disparities, educational programs, and officer training. On appeal, the appellants claim the trial court erred regarding the denial of contact visits, disciplinary procedures, transportation, control facilities, outdoor recreation, and telephone access. The standard of review varies based on the rights at stake. Conditions affecting fundamental interests must be justified by compelling governmental interests under both state and federal Constitutions, subjected to strict scrutiny. Conversely, if a condition does not implicate equal protection or fundamental interests, it can withstand review if reasonably related to a legitimate governmental purpose. The appellants assert that the precedent set in Bell v. Wolfish does not apply to pretrial detainees under the California Constitution due to the fundamental nature of personal liberty, which warrants strict scrutiny for substantial restraints. Restraints on the liberty of pretrial detainees are viewed as a wealth-based classification under the California Constitution, which is considered a suspect classification requiring compelling governmental interest and strict scrutiny. Although a prior decision, In re Smith, held that the inability to post bail does not constitute a denial of equal protection, the current court acknowledges this decision but expresses disagreement with its analysis, emphasizing it cannot overrule it due to the principle of stare decisis. The court recognizes that while factors of wealth influence bail decisions, pretrial detainees are not legally classified as a wealth-based group. It is noted that those who cannot post bail become part of the detention population, where their presumption of innocence remains intact, yet their liberty interests may be limited by necessary security regulations of detention facilities. Judicial evaluations of confinement conditions must balance the need for security against human dignity and constitutional standards, with a focus on whether conditions reflect prohibited punishment rather than legitimate governmental purposes. Absent evidence of intent to punish from officials, assessments will consider if the restrictions serve a rational purpose and whether they are excessive relative to that purpose. A condition or restriction of pretrial detention is not considered "punishment" if it is reasonably related to a legitimate governmental objective, such as maintaining jail security. However, if a restriction is arbitrary or not related to a legitimate goal, it may be viewed as punishment and thus unconstitutional. The management of a detention facility justifies certain restrictions, even if they cause discomfort to detainees awaiting trial. The case of Molar v. Gates clarifies that lawful incarceration does not inherently justify limitations on the constitutional equal protection rights of female inmates, which require heightened scrutiny. While Bell v. Wolfish addresses treatment of pretrial detainees versus sentenced prisoners, it does not apply equally to gender-based classifications. Any differences in treatment based on sex must be justified by compelling governmental interests and will undergo strict scrutiny. Administrative convenience or budgetary considerations cannot justify unequal treatment of female inmates. Courts may consider financial and social costs when addressing equal protection violations, but such considerations cannot excuse infringement of fundamental rights. Pretrial detainees were initially allowed outdoor recreation for four 1-hour sessions weekly in smaller, asphalt-covered areas, while sentenced prisoners had two 1-hour sessions weekly in a larger, partially grassy area. Following the trial, both groups were granted access twice a week for over an hour in the larger space, with maximum security inmates having similar access in a more secure area. Inmates at Los Angeles County detention camps and the California Institution for Women had daily outdoor access. The trial court ruled the previous outdoor time limitations lacked justification but found the new practice legally justified and not in violation of equal protection rights. Appellants argued that the reduction of outdoor time constituted cruel and unusual punishment and that limited access for female prisoners was discriminatory. The court needed to assess if the restrictions aligned with evolving societal standards. It determined that the overall recreational opportunities, including daily access to dayrooms and various activities, met these standards, concluding the restrictions were not unconstitutional. The court found no evidence of punitive intent behind the changes, which aimed to equalize outdoor access for pretrial detainees with sentenced prisoners. Despite acknowledging that two hours weekly was minimal, the court upheld the regulation as justified by legitimate governmental interests. Disciplinary procedures for inmates facing major offenses, such as fighting or insubordination, involve removal to a day room for evaluation by a supervising deputy, who decides on immediate transfer to disciplinary segregation based on security and welfare concerns. The trial court affirmed that immediate transfers occur only when necessary for safety. Appellants argued that the practices violate due process, citing uncontradicted testimony indicating that inmates are routinely placed in isolation prior to a hearing, which typically occurs within 24 hours. While acknowledging the SBI policy allows for such transfers when warranted, they contended this does not reflect actual practices. The court's role is to determine if substantial evidence supports the trial court's findings, which in this case, it concluded there was ample evidence, including the policy manual. Compliance with the manual's procedures ensures that due process is maintained, as long as hearings occur promptly. In administrative segregation, the trial court noted that inmates with combative behavior are segregated through a procedure involving observation, reports, medical checks, and psychiatric evaluations, with the classification board reviewing the need for continued segregation. The court deemed this procedure reasonable and justified by governmental interests, while appellants argued that it failed to meet due process standards by depriving inmates of privileges without sufficient cause. The SBI Manual stipulates that administrative segregation can occur only if a prisoner is deemed an escape risk, assault risk, in need of protection, or a high security risk. Control cell block prisoners face significant deprivations, including solitary confinement, lack of dayroom and television access, and absence of outdoor exercise for extended, unspecified durations. Respondents claim that the existing multi-level review process, verified by medical staff, safeguards against wrongful actions. Due process considerations involve evaluating (1) the private interest impacted by the action, (2) the risk of erroneous deprivation through current procedures and the potential benefits of additional safeguards, (3) the dignitary interest in informing inmates of the reasons for their treatment and enabling them to present their case, and (4) the governmental interest, including administrative and fiscal burdens of additional requirements. In People v. Ramirez, the court emphasized the need for due process in cases of maximum security confinement, highlighting that California's regulations limit classification committee discretion. Consequently, inmates must receive a hearing with advance notice, the chance to present evidence and witnesses, written justification for decisions, and representation for those unable to advocate effectively for themselves. The California Supreme Court extended these due process protections to inmates in administrative segregation facing disciplinary charges in In re Davis, and the First District Court of Appeal similarly applied them to solitary confinement classifications in In re Carr. Pretrial detainees retain constitutional rights akin to those of convicted prisoners, as established in Bell v. Wolfish. Although inmates at SBI are typically segregated for shorter periods than sentenced prisoners, the temporary nature does not diminish the necessity for due process protections. The Davis ruling affirmed that administrative segregation requires hearings with due process safeguards, analogous to those outlined in Enomoto v. Wright. While SBI policy procedures mitigate the risk of wrongful deprivation, they do not replace the need for a hearing that allows inmates to present evidence, provided it does not compromise institutional safety or correctional objectives. Witnesses and evidence can more effectively challenge the factual basis of an original report than the testimony of an affected inmate alone, as established in key cases such as Vitek v. Jones and O'Bryan v. County of Saginaw. Implementing procedural safeguards from Wright v. Enomoto and In re Carr will impose additional administrative burdens on respondents; however, these do not outweigh the essential dignitary interests in informing individuals of the nature and consequences of actions taken against them and allowing them to present their perspectives. To comply with procedural due process, modifications to trial court judgments regarding administrative segregation are necessary, including: (1) a hearing with advance written notice before initial placement, except in emergencies; (2) the opportunity for inmates to present witnesses and evidence; (3) written reasons for placement decisions; and (4) provision of counsel or a substitute for illiterate inmates or complex cases. Regarding court transportation, telephone access, and visitation policies, the trial court justified practices including waking prisoners at 4:30 a.m. for court and limited telephone access through a signup system. The denial of contact visits was also upheld. Appellants argue these conclusions are incorrect, especially concerning pretrial detainees. Besides the required modifications for administrative segregation, the review found substantial evidence supporting the trial court's judgments as of December 6, 1978. Appellants seek to reverse the judgment on various issues related to inmate treatment and request that the superior court conduct further hearings, citing a subsequent federal court decision affecting male inmates in Los Angeles County as a basis for their appeal. In **Rutherford v. Pitchess**, the U.S. District Court for the Central District of California ruled on key constitutional rights for pretrial detainees at Los Angeles County central jail. The court established that these detainees are entitled to: 1) sleep from 8 p.m. to 6 a.m. on trial days; 2) at least one phone call daily; 3) limited "contact" visits with family members; and 4) a minimum of two and a half hours of exercise weekly, aiming for one hour per day. The judgment, filed on February 15, 1979, was later modified on October 20, 1981, following concerns raised by a Los Angeles Superior Court judge about operational disruptions caused by the federal order. The trial court found that differences in treatment between male and female inmates were justified by legitimate governmental interests and supported by substantial evidence. Appellants requested further hearings based on changes in jail conditions since the Rutherford judgment, but conflicting claims about these changes led the court to refrain from such actions, emphasizing the need for decisions based on the existing record rather than unverified allegations. The trial court holds the authority to modify injunctions due to changes in law or facts, as established in precedent cases. Lastly, the trial court awarded $105,760 in attorney fees to the plaintiffs under the private attorney general theory, recognizing their success in vindicating constitutional rights for a significant group of individuals. Attorneys' fees totaling $3,918 were deemed non-recoverable under 42 U.S.C. § 1988, which were specifically related to litigation over the fees themselves. Plaintiffs initially sought $491,594.75 in fees, while defendants argued for a complete denial or a cap of $25,000. Plaintiffs' attorneys documented 2,745 hours of work at a rate of $100 per hour, multiplied by 1.5 for quality, but the trial court reduced the hours to 2,461 and set attorney rates between $50 and $70 per hour, applying a .67 multiplier due to the plaintiffs' lack of success on medical issues. Plaintiffs argued that the trial court erred in not awarding fees under § 1988 but failed to show how this impacted the fee award. Defendants, in a cross-appeal, contended that fees for the application for attorneys' fees should not be included without special circumstances, which they argued were absent in this case. The court noted a lack of California precedent and a split in federal authority, but found support in Rich v. City of Benicia, which permitted fee awards under a "private attorney general" theory to promote significant public policy interests. It emphasized that the trial judge is best positioned to assess the value of legal services and that an appellate court will not overturn this judgment unless clearly erroneous. The court found no abuse of discretion and modified the judgment regarding the procedural requirements for placing an inmate in administrative segregation, mandating a hearing and written decision under specified conditions. A hearing following a genuine emergency must occur within 72 hours after the emergency concludes. The judgment has been modified and affirmed, with Woods, Acting P.J., and Files, J. concurring. Petitions for rehearing were denied on April 14, 1982, and a Supreme Court hearing request was denied on July 14, 1982; Bird, C.J., and Newman, J. believed the petition should be granted. Both parties contested the award of attorneys' fees, discussed later in the opinion. Key statistics indicate that 50% of prisoners booked into the county jail are released within 48 hours and 80% within 10 days. Practices enjoined included restrictions on receiving newspapers, limitations on eating utensils for pretrial inmates, and exclusion of women from the work furlough program. Modifications made included reclassification of inmates' security levels, changes in telephone access procedures, increased library access, expanded law library availability, and access to outdoor exercise areas. Additionally, appellants argued that certain regulations denied them equal protection, supported by evidence of differing conditions at various facilities. A noted discrepancy involved the wake-up time for inmates, which has changed to between 5:30 and 5:45 a.m. Orders from another case have led to a voluntary agreement among most courts to adjust their schedules for the later appearances of in-custody defendants. Although not part of the current record, relevant information is documented in subsequent unreported proceedings of *Rutherford v. Pitchess, U.S.D.C. No. CV-75-4111-WPG*. Changes since the trial include a later bus departure from SBI, now around 7 a.m., and adjustments to inmate wake-up times. Female inmates are awakened between 5:45 a.m. and 5:50 a.m., an improvement from the previous wake-up time of 4:30 a.m. Any deviations from this established practice for court-bound inmates should be reported to the trial court. The applicability of 42 U.S.C. § 1988 to suits in California courts is uncertain, especially considering California Code of Civil Procedure section 1021.5. This matter is currently under review by the California Supreme Court in *Serrano v. Unruh*, with a hearing granted and the case cited as 32 Cal.3d 621.