Brown (formerly Schwarzenegger) v. Plata et al

Brown (formerly Schwarzenegger) v. Plata et al
Brief Filed: 11/10
Court: U.S. Supreme Court
Year of Decision: 2011

Read the full-text amicus brief (PDF, 190KB)


At issue is a lengthy class action case by California prisoners who are mentally ill (and another class for those with physical medical needs) challenging the conditions of their imprisonment due to overcrowding, including lack of adequate mental health services. This case arises under a unique federal statute, Prison Litigation Reform Act (PLRA), which provides in grossly simplified part that if there is a finding of deprivation of constitutional rights that is directly caused by overcrowding, the court can order a release plan. That is what happened in this case when a three-judge district court found that overcrowding in California’s prisons was the primary cause of the failure to deliver constitutionally adequate mental health care to its prison inmates and that no relief other than a reduction in overcrowding would address the violations. These findings came after nearly two decades of litigation. 

California then appealed directly to the U.S. Supreme Court and argues that the district court intruded onto the state’s prerogative in operating prisons. The primary issue before the court is whether the overcrowding finding and order to reduce the prison population from 200 percent to 137.5 percent was premature. The issue of prisoners’ lack of access to mental health care is prominently featured as a theme in the case.

APA agreed to join with the American Psychiatric Association, the American Academy of Psychiatry and the Law, California Psychiatric Association, Judge David L. Bazelon Center for Mental Health Law, Forensic Mental Health Association of California, NAMI and NAMI-California in filing an amicus brief in support of the appellees.

Index Topic

Criminal Defendants’ Right to Mental Health Assistance

APA’s Position

The brief is directed principally at providing a context for the Supreme Court’s evaluation of record evidence that overcrowding is the primary cause of the state’s inability to render constitutionally adequate mental health care. The brief provides both an outline for what is required to provide constitutionally minimal mental health care and an explanation of the ways in which overcrowding — with the burdens it places on facilities, systems and staff — can prevent achievement of that minimal standard.  


On May 23, 2011, the U.S. Supreme Court ruled that California prison overcrowding is the primary cause of Eighth Amendment violations of prisoners’ rights to adequate medical and mental health care. In upholding a three-judge court’s order requiring reduction in the California prison population to relieve overcrowding, subject to the right of the state to seek modification of the order in appropriate circumstances, the court agreed that evidence supported a conclusion that no other relief would remedy the violations.