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Pargo v. Elliott
Citations: 49 F.3d 1355; 1995 WL 107504Docket: No. 94-3399
Court: Court of Appeals for the Eighth Circuit; March 14, 1995; Federal Appellate Court
An appeal was filed by inmates of the Iowa Correctional Institution for Women (ICIW) following an unfavorable judgment in a 42 U.S.C. § 1983 action against Iowa Department of Corrections officials and the ICIW superintendent, claiming violations of equal protection rights due to substantial disparities in prison services and programs compared to male inmates. The trial court determined that the female inmates were not similarly situated to male inmates and that the differences in programs were not due to intentional discrimination. The appellate court found the trial court had applied incorrect legal standards, particularly in assessing whether the plaintiffs had established that gender discrimination influenced program design. The trial lasted six days, with extensive evidence and witness testimonies presented. The trial court issued a brief decision noting "clear differences" in programs without specific findings, ultimately relying on Klinger v. Dep’t of Corrections, which ruled that gender groups could be deemed not similarly situated based on various institutional factors. The appellate court clarified that Klinger does not preclude consideration of certain types of comparisons and noted that the plaintiffs focused on differences among similarly classified inmates regarding access to various programs. The appellate court emphasized the need for the government to justify these differences and criticized the lower court for applying a lower level of scrutiny. The case was vacated and remanded for more detailed factual findings. In Personnel Administrator of Massachusetts v. Feeney, the Supreme Court established that women contesting a law favoring veteran employment must prove invidious discrimination. In Turner, the Court upheld Missouri prison regulations limiting inmates' rights to correspond and marry, prioritizing institutional security. It determined that day-to-day prison management issues are not suitable for judicial intervention, requiring regulations that limit constitutional rights to be rationally related to legitimate penological purposes. Internal security is recognized as a primary legitimate objective under Turner. However, not all prison policy reviews necessitate judicial deference, as seen in Pitts v. Thornburgh, where heightened scrutiny was applied to a policy segregating female inmates in distant facilities. The Turner standard does not exempt prison regulations from judicial review, and courts must acknowledge valid constitutional claims from inmates. The trial court failed to make specific factual findings on program differences between male and female institutions, rendering the matter unreviewable. Consequently, the judgment is vacated and the case is remanded for detailed factual findings, with the trial court tasked to determine the appropriate standard for its conclusions, while the appellate panel retains jurisdiction over the appeal.