Holt v. Sarver

), Judge J. Smith Henley ruled several aspects of Arkansas' existing prison system unconstitutional.

), Judge Henley ruled the entire Arkansas prison system unconstitutional and ordered the State Correction Board to devise a plan of action.

In that same case in 1971, Judge Henley enjoined the Arkansas prison from preventing the inmates' access to court and from inflicting cruel and unusual punishment upon them.

[4][5] The Supreme Court ruled in Jones v. Cunningham in 1963 that inmates in state institutions could file a writ of habeas corpus challenging the conditions of their imprisonment as well as its legality.

[6] Subsequently, in a series of cases starting with Gates v. Collier the federal government began whole scale intervention in the constitutionality of the operation of state prison systems.