Johnson v. California, 543 U.S. 499 (2005)
Primary Holding
Strict scrutiny is the appropriate standard of review for an equal protection challenge to a policy of racially segregating prisoners in California's reception centers, as such segregation based on race is subject to heightened scrutiny under the Fourteenth Amendment.
In the case of Johnson v. California, the Supreme Court ruled that California's policy of separating prisoners by race during their initial 60 days in a new facility was unconstitutional. This matters because it reinforces the idea that people should not be treated differently based on their race, even in prisons, highlighting the importance of equal protection under the law. This case is relevant if someone believes they are being unfairly treated or discriminated against based on race, as it sets a standard that such practices must be closely examined and justified.
AI-generated plain-language summary to help you understand this case
In Johnson v. California, 543 U.S. 499 (2005), the underlying dispute arose from the California Department of Corrections (CDC) policy of racially segregating inmates in double cells during their initial 60 days at reception centers upon entering a new correctional facility. This practice was justified by the CDC as a means to prevent violence associated with racial gangs, which the department claimed were prevalent in its facilities. The policy resulted in inmates being assigned cellmates predominantly of the same race, with the likelihood of being paired with someone of a different race being nearly zero. Garrison Johnson, an African-American inmate, was consistently assigned to double cells with other African-American inmates throughout his incarceration. The procedural history of the case began when Johnson filed a pro se complaint in the United States District Court for the Central District of California on February 24, 1995. He challenged the CDC's housing policy, asserting that it violated his right to equal protection under the Fourteenth Amendment by discriminating against him based on race. Johnson claimed that the policy was unconstitutional and had been enforced by former CDC Director James Rowland. The case eventually made its way to the Supreme Court after being heard by the Ninth Circuit Court of Appeals. Relevant background context includes the CDC's rationale for the segregation policy, which was based on concerns about inmate safety and the potential for racial violence. The CDC identified several major prison gangs that contributed to a violent prison culture, and officials testified that failing to consider race in housing assignments would likely lead to conflicts. However, it is noted that outside of the reception centers, the rest of the prison facilities were integrated, and inmates could choose their cellmates after the initial 60-day period, suggesting a distinction in treatment based on the timing of their incarceration.
Whether strict scrutiny is the proper standard of review for an equal protection challenge to the California Department of Corrections' policy of racially segregating prisoners in double cells during their initial reception period.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 2, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Johnson v. California, 545 U.S. 162 (2005)
Consumer WonTo establish a prima facie case of racial discrimination in jury selection under Batson v. Kentucky, a defendant does not need to show that it is more likely than not that the peremptory challenges were based on impermissible group bias; rather, the defendant must only demonstrate that the circumstances raise an inference of discrimination.
Wilkinson v. Dotson, 544 U.S. 74 (2005)
Consumer WonPrisoners may bring actions under 42 U.S.C. §1983 to challenge the constitutionality of state parole procedures, rather than being required to seek relief exclusively through federal habeas corpus statutes.
Johnson v. United States, 544 U.S. 295 (2005)
Consumer LostThe period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.
Wilkinson v. Austin, 545 U.S. 209 (2005)
Mixed OutcomeThe procedures adopted by Ohio for classifying prisoners and assigning them to its Supermax facility comply with the due process requirements of the Fourteenth Amendment.