Rhodes v. Chapman
The spectacular rise in the criminal convictions in the last three
decades has resulted in the overcrowding of prison institutions not only in the
United States but also all over the world. Obviously, public and government
attitude favors imprisoning convicted criminals for as long as possible.
Unfortunately, this general attitude has caused a significant increase in
prison population, thus forcing prison-reform groups and the inmates themselves
to file protests and lawsuits against the state governments and penal
administrators. Critics, however, claim that if shared tents and small quarters
are good enough for the National Guard, Marines, and Army, then a one-man cell
shared by two inmates is certainly good enough for the inmates. All the same,
because of some of the disturbing conditions brought about by the practice of
housing two or more prisoners in a single cell in many penal institutions,
judges are becoming more compassionate to the argument that this practice
indeed amounts to cruel and unusual punishment. Most of these judges are
drawing the meaning of cruel and unusual punishment from the evolving ideals of
decency of a maturing society. However, even though nowadays double celling is
somewhat a restrictive form of punishment, it is without a doubt not a cruel
and unusual punishment, but only part of the consequence that criminals
necessarily forfeit for their wrongdoings against society.
Overview of the Eight Amendment
The Eight Amendment of
the United States Constitution states that Excessive bail shall not be
required, nor excessive fines imposed, nor cruel and unusual punishments
inflicted (Head, 2010). By looking at the wordings of this Amendment, it is
very evident that prohibition against barbarous punishments and tortures were
clearly on the minds of the members of congress at the time of the Amendments
deliberation. The Eight Amendment basically enforces restriction upon
punishmentsthat they cannot be unusual or cruel. It embodies idealistic and
broad concepts of decency, humanity, civilized standards and dignity, against
which conditions of detention must be judged (Rhodes v. Chapman, 1981). Hence,
the realization of the Eight Amendment was very significant because most of the
early Americans were very concerned with the practice of disproportionate and
arbitrary punishment. In fact, from the time of the Amendments implementation,
the most frequently cited part of the Amendment is the part that deals with its
prohibition against unusual and cruel punishment.
The very nature of the
cruel and unusual phrase depends on the evolving societal standards. Throughout
the years, the Court has construed the Eight Amendment in a dynamic and
flexible manner, and it has even extended its interpretation beyond the
barbaric physical punishments. The Amendment is continually taking a vital and
expansive nature by drawing its interpretation from the developing standards of
decency, which is a mark of a growing society. Accordingly, because of the
importance and attractiveness of the Eight Amendment, it has become the most
modified amendment among all the amendments in the Constitution in terms of
scope and standards (Head, 2010).
In modern years, the fundamental legal question on cruel and unusual
punishment was answered by the United States Supreme Court in the landmark case
of Rhodes vs. Chapman (1981). The Court has explained that inhumane prison
conditions can violate the Eight Amendment, although such limitation is not
mentioned in the official wordings of the provision. Furthermore, the Court
clarified that the Eight Amendment is violated, even though the punishment is
not physically barbaric, as long as it involves a wanton and unnecessary
imposition of pain, or is abhorrently inconsistent to the severity of the
crime. In view of these justifications, the Eight Amendment undeniably denotes
de facto punishments, whether they are formally passed on as punishment or not
(Head, 2010).
Overview of the Fourteenth Amendment
The Fourteenth
Amendment of the United States Constitution was principally designed to protect
the civil liberties of and grant citizenship to recently freed slaves. The
heart of the amendment is its first section, which declared that all person born or naturalized in the United States to be both national
and state citizens, and which prohibited the states from abridging their
privileges and immunities, depriving any person of life, liberty, or property
without due process of law, or denying them equal protection of the laws.
(Foner, 2004)
Since the Bill of Rights, the Fourteenth Amendment was considered by
many as the most significant constitutional change in the history of the United
States. In accordance with the due process and equal protection of the laws
imposed by the Fourteenth Amendment, the Supreme Court made a ruling in Louisiana
v. Resweber that the due process clause of the Fourteenth Amendment shall
incorporate all of the substantive protections of other amendments, including
Eight Amendments cruel and unusual punishment clause. Accordingly, through this
pronouncement, states can apply the cruel and unusual punishment clause of the
Eight Amendment through the due process clause of the Fourteenth Amendment of
the Constitution.
Overview of Southern Ohio Correctional Facility
Southern Ohio
Correctional Facility is a maximum-security state prison in Lucasville, Ohio.
The facility wasbuilt during the early 1970s which holds 1,620 cells, school
rooms, workshops, gymnasiums, library, barbershop, commissary, a hospital ward,
two chapels, and day rooms (Rhodes v. Chapman, 1981). In addition, the outdoors
have a garden, visitation area, and a recreational field. Each cell at the
facility measures about 63 square feet with toilet, sink with hot and cold
running water, night stand, and two beds. In addition, every cell has an air and
heating circulation vent, and almost all of the cells have a window that
inmates can utilize. Moreover, all of the cells have a radio, shelf and a
cabinet built into their walls, as well as one wall of all cells is made of
bars through which the inmates can be viewed. Considering all of these
provisions, the District Court has illustrated the correctional facility of
Southern Ohio as undoubtedly a top-flight, first rate facility (Rhodes v.
Chapman, 1981).Facts of Rhodes v. Chapman
Kelly Chapman, who was
imprisoned for armed robbery, along with his inmate, Richard Jaworski, brought
a class suit in the District Court against the state officials responsible for
the administration of the Southern Ohio Correctional Facility by claiming that
they are violating the constitutional provision against unusual and cruel
punishment (Rhodes v. Chapman, 1981). They brought this action on behalf of
themselves and of all the other inmates housed in this correctional facility
because of the latters practice of housing two inmates for every one-man cell.
Chapman asserted that the one-man cell he shared with Jaworski provided him a
personal space of only 32 square feet. Chapman claimed that such space was less
than what the state of Ohio demands for five-week-old animals in feed lots
(Rhodes v. Chapman, 1981). In short, the action was filed because of Chapmans
claim that the cell mates in the facility were confined too closely, which
violated their constitutional rights against cruel and unusual punishment.
Accordingly, the respondents sought an injunction barring petitioners from
permanently housing more than one inmate in a cell designed for one inmate.Issue
Whether or not the
utilization of double celling at prison is a cruel and unusual punishment
proscribed by the Eight Amendment, as made applicable through the Fourteenth
Amendment of the United States Constitution.Ruling
The District Court
through Judge Timothy Hogan conducted extensive findings of fact regarding the
correctional facility on the basis of a surprised inspection that the court
carried out as well as of the evidence offered at trial (Rhodes v. Chapman,
1981). The findings of the court, which were not contended as erroneous by
either party, described the inmate population, the physical plant, and the
double celling in the Southern Ohio Correctional Facility. Although the overall
findings of the court was positive as it declared that the correctional
facility is indeed a top-flight, first-class facility, the court all the same
concluded that the double celling in question has violated the Eight Amendment
of the Constitution and that it is a cruel and unusual punishment (Rhodes v.
Chapman, 1981). This decision of the Federal District Court was based on five
considerations
the fact that the double celling in question was a permanent condition
the recommendations that inmates placed in double celled quarters spend
most of their time in their cells with their cell inmates
the proposal of a number of studies that every inmate should have no
less than 555 square feet of living quarters
the prison accommodated roughly 38 percent more inmates than its
intended capacity and
prison inmates were serving lengthy imprisonment terms (Rhodes v.
Chapman, 1981).
Accordingly, the
District Court enjoined the relocation of some inmates from Southern Ohio
Correctional Facility awaiting a final decision. Because of the aforesaid
decision, Governor James Rhodes elevated the case to the Court of Appeals,
Sixth Circuit, on account of the state. The appellant claimed that the
conclusion of the District Court indicates that double celling is per se
unconstitutional when in actual fact it is not. Nevertheless, the appellate
court declared that the decision of the District Court on double celling as
violation of the constitutional provision against unusual and cruel punishment
reads that it is not per se unconstitutional, but applicable only under the
circumstances at Southern Ohio Correctional Facility. Therefore, the Court of
Appeals held that District Courts conclusion is not erroneous and affirmed its
findings. As a result of the appellate courts findings, the petitioners further
elevated the case to the Supreme Court, praying that the original decision be
reversed.
Supreme Court
Taking into
consideration the findings of fact of the District Court, the United States
Supreme Court held that double celling employed in prison is not tantamount to
cruel and unusual punishment. The Court concluded that all the considerations
on which the District Court and Court of Appeals hinged on are not enough to
sustain their constitutional conclusion. Basic is the rule that conditions of
confinement must not be abhorrently inconsistent to the evilness of the crime
justifying imprisonment, nor may they involve infliction of wanton or
unnecessary pain (Rhodes v. Chapman, 1981). However, the lower courts have
failed to prove cruel and unusual punishment because of the absence of any the
aforesaid conditions that can justify double celling as unconstitutional.
Upholding the findings of the lower court would only confirm the erroneous
assumption that double celling inflicts pain and per se unconstitutional. In
fact, the Supreme Court found that the imposition of double celling did not
result in confiscations of basic sanitation, medical care, or food, nor did it
intensify violence among inmates or produce other unbearable conditions for
prison confinement.
The law mandates that
prison officials may not use unwarranted physical force against the prison
inmates, and must make sure that the inmates receive sufficient medical care,
shelter, clothing, and food, as well as take reasonable measures to ensure the
wellbeing of the inmates. Southern Ohio Correctional Facility, having
characterized as a top-flight, first rate facility, has certainly not fallen
short of the aforesaid responsibilities. The law does not mandate to provide
the inmates with comfortable prisons since any person convicted of serious
crimes cannot be unconstrained of discomfort. The Eight Amendment of the
Constitution only imposes limitation upon punishment, which cannot be unusual
and cruel. Among the wanton and unnecessary inflictions of punishment are those
that have no penological reason. In the given case, however, Supreme Court
found that there is a clear absence of infliction of excessive or unnecessary
pain or force to the inmates. Therefore, the Supreme Court reversed the
judgment of the Court of Appeals there being no violation of the Eight and
Fourteenth Amendments.
Personal Assessment
Society must reprimand
those people who contravene its legally imposed rules. However, the punishment
must always be applied within the boundaries laid down by the Constitution. The
conditions of imprisonment of criminals must not entail unnecessary and wanton
infliction of pain, nor may the conditions be grossly disproportionate to the
evilness of the crime justifying imprisonment. The confinement of a person into
a prison institution is without doubt a form of punishment, thus it is subject
to the examination under the Eighth Amendment standards of the Constitution.
State governments must, therefore, be sensitive to the required standard of the
Amendment by providing inmates their medical needs, healthy and safe
environment, and a setting that uphold their welfare. However, it is an
accepted fact that the conditions enforced inside the prison institutions are
not comparable with societys civilized standards of modern life. All the same,
the facts reveal that the conditions inside the Southern Ohio Correctional
Facility are not unusual or cruel, and under present-day standards they should
not be regarded as unconstitutional. Double celling is only part of the
punishment that convicted criminals pay off for their evil doings against
society.
The Eight Amendment of
the United States Constitution enforces that punishment cannot be unusual or
cruel. The definition on cruel and unusual punishment was answered by the
United States Supreme Court in the landmark case of Rhodes vs. Chapman. The
issue raised in this given case was whether or not double celling at prison is
a cruel and unusual punishment proscribed by the Eight Amendment, as made
applicable through the Fourteenth Amendment, of the United States Constitution.
The Supreme Court held that there was no cruel and unusual punishment because
of the simple fact that the inmates conditions of confinement are not
abhorrently inconsistent to the evilness of the crime that justified their
imprisonment, nor their conditions involved infliction of wanton or unnecessary
pain. The law does not mandate the state governments to provide their inmates
with comfortable prisons since any person convicted of serious crimes cannot be
freed from any discomfort. The Eight Amendment of the Constitution only imposes
limitation upon punishment, which cannot be unusual and cruel. Therefore,
although to some extent, double celling may be viewed as restrictive, yet it is
not cruel and unusual punishment, but only part of the consequence that
criminals are made to endure for their wrongdoings against society.
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