Wilkinson v. Austin, 545 U.S. 209 (2005)
Primary Holding
The procedures adopted by Ohio for classifying prisoners and assigning them to its Supermax facility comply with the due process requirements of the Fourteenth Amendment.
In the case of Wilkinson v. Austin, the Supreme Court decided that Ohio's rules for classifying prisoners and sending them to a high-security prison, known as a Supermax facility, are fair and follow the law. This matters because it sets standards for how inmates should be treated and ensures they have a fair process before being placed in such restrictive conditions. This case is relevant if someone is concerned about their rights or the treatment of inmates, especially regarding how they are assigned to high-security facilities.
AI-generated plain-language summary to help you understand this case
In Wilkinson v. Austin, the case centers around the classification process used by the Ohio Department of Rehabilitation and Correction for inmates assigned to the Ohio State Penitentiary (OSP), the state's only Supermax facility. This facility, which opened in 1998 following a riot at another maximum-security prison, is designed to house the most dangerous prisoners under highly restrictive conditions. Inmates at OSP are subjected to extreme isolation, spending 23 hours a day in single-inmate cells, with limited opportunities for recreation, communication, and visitation. The conditions are more severe than those in other forms of incarceration in Ohio, including death row and administrative control units, with placement at OSP being indefinite for inmates serving life sentences. The procedural history of the case began when Charles E. Austin and other inmates challenged the constitutionality of the procedures used to classify inmates for placement at OSP, arguing that these procedures violated their rights under the Fourteenth Amendment. The case was brought before the United States District Court for the Northern District of Ohio, which ruled on the matter before it was appealed to the United States Court of Appeals for the Sixth Circuit. The Supreme Court granted a writ of certiorari to review the decision of the Sixth Circuit, focusing on the adequacy of the procedural protections afforded to inmates prior to their assignment to the Supermax facility. The background context highlights the increasing prevalence of Supermax prisons across the United States, with about 30 states operating such facilities in response to rising prison violence and gang activity. The OSP was established as a means to segregate the most predatory inmates from the general prison population, reflecting a broader trend in corrections towards more restrictive confinement practices. The case raises significant questions about the balance between prison security and the due process rights of inmates facing such extreme conditions of confinement.
Whether the procedures Ohio has adopted for classifying prisoners and assigning them to a Supermax facility comply with the due process requirements of the Fourteenth Amendment.
The judgment of the Court of Appeals is affirmed in part and reversed in part, and the case is remanded for further proceedings consistent with this opinion.
- Court
- Supreme Court
- Decision Date
- March 30, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Kennedy
- Damages Awarded
- N/A
- Data Quality
- high
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. California, 543 U.S. 499 (2005)
Consumer WonStrict 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.
Bell v. Thompson, 545 U.S. 794 (2005)
Consumer LostThe Court of Appeals abused its discretion by withholding its mandate for more than five months after the denial of certiorari without entering a formal order.
Brown v. Payton, 544 U.S. 133 (2005)
Consumer LostThe Supreme Court held that the Ninth Circuit's decision granting habeas relief was contrary to the limits on federal habeas review imposed by 28 U.S.C. § 2254(d), affirming that the jury instructions in the penalty phase of Payton's trial were not constitutionally deficient and did not prevent the jury from considering all relevant mitigation evidence.