Rufo v. Inmates of Suffolk County Jail (1991)

Docket
90-954
Decided
1991-01-01

Summary

Question: Does the court require a grievous wrong evoked by new and unforeseen change of facts in order to modify a consented decree? Conclusion: No, Justice Byron R. White delivered the opinion of the 6-2 majority. The Court held that the grievous wrong standard does not apply to requests to modify consent decrees and that changes of conduct or conditions may be revised if necessary for future events based on a flexible standard. Under a flexible standard, the party seeking modification of an institutional reform consent decree must establish that a significant change in facts or law warrants a revision of the decree and that the proposed modification is tailored to that change of circumstances. This requirement will be satisfied if the change was unforeseen or would be detrimental to public interests without the modification. Justice John Paul Stevens, with whom Justice Harry A. Blackmun joined, wrote a dissenting opinion in which he argued that after the institution was found by the district court to be deficient, it is the district court’s duty to command an effective remedy. In this case, the remedy was to have single-occupancy cells for pretrial detainees and it is important that the court apply a strict standard when considering modification request that undermines the central purpose of a consent decree. The modification of the consent decree should be denied. Justice Clarence Thomas took no part in the consideration or decision.

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