Alabama v. Pugh

Background

Respondents are inmates or former inmates who sued the State of Alabama, the Alabama Board of Corrections, and several prison officials. They alleged that prison conditions were cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The District Court issued an order with measures to remedy the conditions, and the Court of Appeals affirmed but modified parts it thought exceeded the court’s remedial power.

Reasoning

The specific question before the Court was whether a mandatory injunction against the State and its Board violated the Eleventh Amendment’s protection against private suits by citizens against a State. The Court noted that such immunity bars suit unless the State consents. Respondents did not claim Alabama had consented, and the Alabama Constitution provides that the State cannot be made a defendant. The Court therefore granted review limited to that question, reversed in part, and remanded with instructions to dismiss the State and its Board from the case.

Real world impact

As a result, the State of Alabama and the State Board of Corrections are removed as named defendants. Court-ordered remedies aimed at correcting prison conditions remain directed at individual officials and continue to be in effect. The dismissal reduces the risk that the State itself could be held in contempt for failing to comply with the mandatory injunction. The appellate court must carry out the Supreme Court’s instruction on dismissal.

Dissents or concurrances

Justice Stevens dissented, arguing the change is a harmless error and will not affect relief. Justices Brennan and Marshall also dissented.