Bell v. Wolfish

Bell v. Wolfish, 441 U.S. 520 (1979), is a case in which the United States Supreme Court addressed the constitutionality of various conditions of confinement of inmates held in federal short-term detention facilities.[1] The Court narrowly found[2] that while treatment of pre-trial detainees is subject to constraint by the First, Fifth, and Fourteenth Amendments,[2] all of the policies challenged in the case passed constitutional scrutiny.[1]

Bell v. Wolfish
Supreme Court of the United States
Argued January 16, 1979
Decided May 14, 1979
Full case nameGriffin Bell, Attorney General, et al. v. Wolfish, et al.
Citations441 U.S. 520 (more)
99 S. Ct. 1861; 60 L. Ed. 2d 447; 1979 U.S. LEXIS 100
Case history
PriorU.S. ex rel. Wolfish v. Levi, 439 F. Supp. 114 (S.D.N.Y. 1977), aff'd in part, rev'd in part sub nom. Wolfish v. Levi, 573 F.2d 118 (2d Cir. 1978); cert. granted, 439 U.S. 816 (1978).
SubsequentVacated and remanded, Wolfish v. Levi, 681 F.2d 803 (2d Cir. 1981).
Holding
The Fourth Amendment does not prohibit strip searches and similar intrusive conduct against persons being held in federal prison while awaiting trial.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityRehnquist, joined by Burger, Stewart, White, Blackmun
Concur/dissentPowell
DissentMarshall
DissentStevens, joined by Brennan
Laws applied
U.S. Const., amend. IV

Factual background

Inmates at the Metropolitan Correctional Center (MCC) filed a class action suit challenging the constitutionality of several conditions of their confinement.[3] Opened in 1975 in New York City, the MCC served as a federally-operated short-term detention facility mainly for defendants awaiting trial at one of three federal district courts located in the New York City area.[3] Though the MCC was initially constructed to house some 449 inmates, administrators were quickly forced to double-bunk inmates to accommodate the "unprecedented" increase in new detainees.[3] In their complaint, petitioners argued that this practice of double-bunking inmates awaiting trial was unconstitutional. They also made claims against various MCC policies, including the "undue length of confinement, improper searches, inadequate recreational, educational, and employment opportunities, insufficient staff, and objectionable restrictions on the purchase and receipt of personal items and books."[3]

Procedural history

After certifying the case as a class action, the U.S. District Court for the Southern District of New York enjoined the MCC practices challenged by petitioners,[4] holding that inmates could only be deprived of liberty as a matter of "compelling necessity."[5] On appeal, the U.S. Court of Appeals for the Second Circuit affirmed nearly all of the District Court's rulings, including the due process standard the District Court utilized in enjoining the MCC's practices.[6] The Court of Appeals did not affirm the District Court's Eighth Amendment analysis related to convicted inmates at the MCC awaiting sentencing or transfer, and instead remanded that issue to the District Court.[7]

The Supreme Court of the United States granted certiorari on October 2, 1978.[8]

Majority opinion

Double-bunking

In its majority opinion, the Supreme Court reversed the Court of Appeals. First, it noted that the “compelling necessity” standard on which the Court of Appeals relied was not grounded in the Constitution.[3] Rather, the Court held, in order to evaluate whether conditions of pre-trial confinement violate an inmate's guarantee of due process, a court must determine whether those conditions “amount to punishment of the detainee”.[9] Because the MCC's practice of double-bunking did not amount to punishment, the policy did not violate the due process clause of the Fifth Amendment.[2][3]

Other challenged practices

The Court also determined that the policy of prohibiting detainee from receiving hard-cover books not mailed directly from the publisher did not violate the First Amendment.[10][11] In addition, the Court held that the practice of prohibiting detainees from receiving packages from outside the facility was not a due process violation under the Fifth Amendment.[10][11] Nor, in the Court's opinion, was the practice of performing body cavity searches on detainees after contact visits a violation of the Fourth Amendment.[10][11]

Finally, the Court held that none of these practices constituted punishment within the meaning of the Fifth Amendment.[11]

References
  1. Bell v. Wolfish, 441 U.S. 520, 523 (1979).
  2. (by a 5–4 decision in part and a 6–3 decision in the other part)
  3. Bell, 441 U.S. at 523–25.
  4. Gill, Joseph P. (1981). "Confused Concepts of Due Process for Pretrial Detainees - the Disturbing Legacy of Bell v. Wolfish". Am. Crim. L. Rev. 18: 469, 472–73.
  5. United States ex rel. Wolfish v. Levi, 439 F. Supp. 114, 124 (S.D.N.Y. 1977).
  6. Wolfish v. Levi, 573 F.2d 118 (2d Cir. 1978).
  7. Bell, 441 U.S. at 530.
  8. 439 U.S. 816 (1978).
  9. Bell v. Wolfish, 441 U.S. 520, 535 (1979).
  10. Hassler, Keith A. (1979). "Case Comment -- Bell v. Wolfish: The Rights of Pretrial Detainees". New England Journal on Prison Law. 6: 129, 134.
  11. Boyle, James Brian (1981). "Bell v. Wolfish (Comment)". N.Y. L. Sch. L. Rev. 26: 341, 355–57.

Further reading

Journal articles
  • Keith A. Hassler, Bell v. Wolfish: The Rights of Pretrial Detainees, 6 New Eng. J. on Prison Law 129 (1979)
  • Dennis D. Cohen, Substantive Due Process Rights of Pretrial Detainees after Bell v. Wolfish, 65 Iowa L. Rev. 818 (1980)
  • Joseph P. Gill, Confused Concepts of Due Process for Pretrial Detainees - the Disturbing Legacy of Bell v. Wolfish, 18 Am. Crim. L. Rev. 469 (1981)
  • James Brian Boyle, Constitutional Law--Pretrial Detention--Due Process--Bell v. Wolfish, 26 N. Y. L. Sch. L. Rev. 341 (1981)

Judicial opinions
  • Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015)
  • Florence v. Bd. of Chosen Freeholders of Cty. of Burlington, 566 U.S. 318 (2012)
  • Turner v. Safley, 482 U.S. 78 (1987)
  • Johnson v. Phelan, 69 F.3d 144 (7th Cir. 1995)
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