Court: District Court, E.D. Tennessee; March 16, 1989; Federal District Court
A class action trial was held on March 6, 1989, addressing the causes of overcrowding at the Jail and the Intake Center, as well as potential injunctive relief. The court adopted prior findings from a January 25, 1989 opinion, stating that since October 1985, Tennessee has allowed an increasing number of TDOC-sentenced inmates to remain in county jails, with approximately 2,300 currently housed in these facilities. This has led to overcrowding, as evidenced by 147 TDOC-sentenced inmates awaiting transport, which contributes to conditions exceeding capacity.
Testimony from Commissioner W. Jeff Reynolds indicated that the state has not acted to alleviate overcrowding despite being aware of the situation, and the county defendants lack the authority to reduce the inmate population unilaterally. The court concluded that the county defendants could not address overcrowding without state intervention. Despite a federal court order limiting inmate numbers in the Tennessee State Prison System since December 1985, only 300 additional beds have been added, leaving a projected deficit of over 1,000 beds. Reynolds noted that the state plans to continue housing at least 2,500 TDOC-sentenced inmates in county jails into the early 1990s, with no emergency measures implemented to address the crisis. An expert witness for the state acknowledged that the policy of retaining TDOC-sentenced inmates in local jails is not aligned with sound corrections policy.
Cox opined that the Tennessee Department of Corrections (TDOC) practices since October 1985 align with good corrections policy; however, his opinion lacks a review of the state’s adopted solutions and does not assess current versus future capacity needs. He did not provide projections for the overall needs of Tennessee or evaluate the adequacy of the state’s building program. Evidence from hearings in August 1988 and March 1989 indicated that removing TDOC-sentenced inmates from the Knox County Jail and Intake Center would bring these facilities within their rated capacities, thereby addressing unconstitutional conditions.
Due to a backlog of TDOC-sentenced inmates and a state payment program for local jails, the Knox County Sheriff’s Department faced a revenue shortfall of about $1 million for the fiscal year 1988-89, necessitating budget cuts in law enforcement and personnel. The state reimbursed the jail an average of $13.91 per day for housing inmates, while the actual cost was $36.57 per day.
The court’s conclusions of law adopted from its January 25, 1989, opinion state that the state's policy allowing TDOC-sentenced inmates to remain in local facilities for extended periods causes unconstitutional conditions. The court mandates the removal of additional TDOC-sentenced inmates to reduce the jail population to TCI-rated capacities—228 for the Jail and 127 for the Intake Center. The state defendants must remove 80 inmates by March 23, 1989, and additional inmates by May 30, 1989, with a requirement to simultaneously remove an inmate for each additional TDOC-sentenced inmate housed.
While the court limits inmate housing to TCI-rated capacities, it allows temporary exceedance by 15% for up to five consecutive days or ten days within thirty days. Additionally, the drunk tank in either facility cannot exceed 16 inmates at once or hold any inmate for more than 48 hours.
Inmates cannot be housed in the drunk tank for more than two days within any 30-day period. The court references Roberts v. Tennessee Department of Correction, expressing confidence that state officials can manage inmate populations without resorting to mass releases, despite concerns raised by the state about overcrowding. Commissioner Reynolds indicated that 200 beds are available statewide for TDOC-sentenced inmates. The court asserts that managing inmate release is a state responsibility and does not fall under federal jurisdiction. It emphasizes that the state must meet constitutional standards for incarceration and be accountable to the public if it fails to do so. The ongoing supervision by the United States District Court in Nashville over state prison operations is noted, but the court insists that issues specific to the Knox County jail should be addressed locally, as transferring cases would not resolve the underlying problems and would only cause delays. The court highlights that the presence of TDOC-sentenced inmates is a primary factor in the jail's overcrowding, reinforcing its earlier findings. The state defendants' claims of being denied the opportunity to present evidence on this matter were acknowledged, leading to further hearings for both state and county defendants.
The court previously ordered, on February 24, 1989, that the State must remove 80 TDOC-sentenced inmates within 30 days, as discussed during a status conference on February 21, 1989. This removal number and timeframe were proposed by the state defendants in their plan to address overcrowding in Knox County facilities. The court highlights that this decision was not made arbitrarily, as the State expressed concerns that the order would negatively impact other counties. The term 'simultaneously' is defined such that the Knox County Sheriff must inform Howard Cook or his designee upon receiving any newly-sentenced TDOC inmate. Following this notification, the state defendants are then required to remove the TDOC-sentenced inmate with the earliest effective sentence date from the Knox County jail within three working days. The county defendants must then transfer that inmate to the custody of the state defendants.
