Costello v. Wainwright

Background

A group of prisoners in Florida challenged extreme overcrowding, saying it violated the Eighth Amendment’s ban on cruel and unusual punishment. A single District Judge found serious constitutional problems and issued a preliminary order requiring the state’s corrections agency to reduce the inmate population or increase prison capacity. The federal appeals court (en banc) threw out that order, saying only a three-judge panel under 28 U.S.C. § 2281 could grant such relief.

Reasoning

The key question was whether the three-judge-panel rule applied here. The Court explained that the federal statute requiring three judges applies when a state law is directly alleged to be unconstitutional, not simply when a court’s equitable remedy might affect duties imposed by valid state laws. Because the original complaint did not challenge a state statute, a single District Judge properly exercised full jurisdiction. The Court therefore reversed the appeals court, denied the motion to strike the United States’ amicus brief, granted the writ of certiorari and in forma pauperis motion, and sent the case back for further proceedings.

Real world impact

The decision means federal judges can address unconstitutional prison conditions without automatically convening slower three-judge panels when no state law itself is being attacked. Prisoners and state prison officials are most immediately affected, because this ruling allows quicker consideration of remedies for overcrowding. The judgment is procedural and the case returns to lower courts for further work on the merits and possible appeals.