Hadix v. Johnson.

U.S. Appeals Court

CONSENT DECREE-TERMINATION

Hadix v. Johnson, 367 F.3d 513 (6th Cir. 2004). State inmates filed a class action under [section] 1983 alleging that their conditions of confinement violated their constitutional rights. Their claims were settled by a consent decree. The district court denied prison officials' motion to terminate the consent decree and issued an injunction ordering the departmentalization of facilities as a fire safety remedy. The officials appealed. The appeals court affirmed in part, reversed in part, and remanded. The appeals court held that the consent decree encompassed the cell blocks in question but that the district court judge abused his discretion when he found that current conditions violated the Eighth Amendment, because the court incorporated its principal findings from two years earlier, despite the fact that a number of issues had since been resolved. The appeals court also noted that the district court did not state the standard it was applying to find that conditions relating to fire safety and fire prevention were inadequate, and failed to identify the point at which certain fire safety deficiencies ceased being mere deficiencies and instead became constitutional violations. (State Prison of Southern Michigan, Central Complex)