Brown v. Plata, 563 U.S. 493 (2011), was a decision by the Supreme Court of the United States holding that a court-mandated population limit was necessary to remedy a violation of prisoners’ Eighth Amendment constitutional rights.

[4] In June 1994 the magistrate judge found that defendants’ delivery of mental health care to class members violated the Eighth Amendment to the United States Constitution.

[4] As a result, the court ruled in June 2005 and issued an order on October 3, 2005, putting the CDCR's medical health care delivery system in receivership.

[6] In 2006, the plaintiffs in the Coleman and Plata cases filed motions to convene a three-judge court to limit the prison population.

[18] Sacramento native Justice Anthony Kennedy wrote for the Court, first chronicling the troubled 11 years California prisons operated near 200% of design capacity.

[20] Because "prisoners retain the essence of human dignity inherent in all persons", the courts have a responsibility to remedy violations of the Eighth Amendment's prohibition against cruel and unusual punishment.

Adequate staffing is unfeasible because prisons had a 54% vacancy rate for psychiatrists and they already "would hire any doctor who had ‘a license, a pulse and a pair of shoes’.

While the two-year deadline may not be feasible, Kennedy notes that California has already made progress in reducing overcrowding and that it asked the court to reverse, not extend, the order.

[20] Justice Antonin Scalia disagreed with the Court majority so strongly that he spent over nine minutes after the Opinion Announcement reading his dissent from the bench.

[20] Since judges' factfinding is traditionally for past or present facts, Scalia thinks it is proper only for elected policy officials to make "broad empirical predictions".

[27] Because this "structural injunction" made such predictions about the future, Scalia writes "the policy preferences of three District Judges now govern the operation of California's penal system.

"[28] While Scalia acknowledges that the PLRA explicitly contemplates prospective prisoner release orders, he feels that this reading of the statute should be construed so as to not "veer significantly from the historical role" of the courts.

[20] Lampooning Kennedy for stating the obvious, Scalia speculates that the majority is attempting to rein in some headstrong judges and that "a warning, if successful, would achieve the benefit of a marginal reduction in the inevitable murders, robberies, and rapes to be committed by the released inmates.

Alito believes the prison capacity ratio imposed by the three-judge court will order "the premature release of approximately 46,000 criminals-the equivalent of three Army divisions.

Because "prospective relief must be tailored to present and future, not past, conditions" Alito feels the court needed to extend its factfinding beyond when it closed discovery.

"[31] Finally, Alito does not believe the three-judge court met the PLRA requirement to give substantial weight to any adverse impact on public safety.

[32] Alito warns "I fear that today's decision, like prior prisoner release orders, will lead to a grim roster of victims.

After the case was argued but before Court issued its opinion the California legislature passed the 2011 Public Safety Realignment initiative, or AB 109.

The state released a white paper on "The Future of California Corrections" known as "The Blueprint" which planned on seeking the kind of order modification Justice Kennedy had anticipated.

[19] Governor Jerry Brown then announced that the prison crisis had been resolved, terminated his emergency powers, and asked to modify the court order.

[38] Judge Reinhardt even appended to his opinion a table of state laws, including appropriation limits, that were now "waived" so that the governor could obey his order.

[43] The state must still submit monthly updates to the Three Judge Court regarding population reduction and other efforts to implement the decision.

The Program Guide, which is the remedial implementation plan for Coleman v. Brown, mandated the following: "1) Any inmate referred to a Mental Health Crisis Bed must be transferred within 24 hours of referral; 2) Any inmate referred to any acute inpatient mental health placement be transferred within ten days of referral, if accepted by Department of State Hospitals; 3) Any inmate referred to any intermediate health care placement be transferred within 30 days of referral, if accepted by the Department of State Hospitals.

"[57] On April 19, 2017, Judge Kimberly Mueller held that the state was not in compliance with the Program Guide timelines for transfers to mental health care facilities.

[57] On February 21, 2018, the state appealed this order to the Ninth Circuit, claiming that the District Court "abused its discretion because perfect compliance with the Program Guide is not relief that is necessary to correct a systemic Eighth Amendment violation" and that if "the April 19 Order also mandated perfect compliance with the 24-Hour MHCB transfer timeline, then such a ruling also fails to comport with the Eighth Amendment and PLRA.

[63] Responding to the poll, Bruce Peabody, professor of political science at Fairleigh Dickinson University said the Court's ruling was "somewhat surprising."

He added "While our current Supreme Court has a mixed record with respect to recognizing various rights of those accused of crimes, it has generally declined to give extensive constitutional protections to those already behind bars… the Court has gone against the wishes of eighteen states who asked for more deference on the issue, and [as a result] it has extended rights to a group – prisoners – who have historically not received much judicial protection.