MARIE DEAN ARRINGTON, PETITIONER,
v.
LOUIE L. WAINWRIGHT, SEC. OF DEPT. OF CORRECTIONS; MARTA VILLACORTA, SUPERINTENDENT OF BROWARD CORRECTIONAL INSTITUTION, AND JIM SMITH, ATTY. GENERAL, RESPONDENTS
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Marie Dean Arrington, an inmate, petitioned for a writ of mandamus challenging her placement in close management confinement at a Florida correctional facility. The Fourth District Court of Appeal granted the petition, holding that while prison officials generally deserve deference regarding internal security decisions, due process requires a hearing to determine whether the inmate should remain in close confinement.
The court granted the petition for mandamus and directed respondents to conduct a hearing within thirty days to determine whether petitioner should remain in close management, as required by both the Florida Administrative Code and the Due Process Clause of the Fourteenth Amendment. The court rejected the equal protection and cruel and unusual punishment claims while still requiring the due process hearing.
[1] A writ of mandamus may be granted to compel a hearing on whether an inmate should remain in close management.
[2] The State may justify placing inmates in close confinement based on a rational basis bearing a substantial relation to public safety, absent a suspect classification.
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Join FLexlaw to unlock all legal intelligence“Prison officials must be free to take appropriate action to ensure the safety of inmates and corrections personnel and to prevent escape”
Establishes the legitimate penological interest supporting close confinement policies
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Join FLexlaw to unlock all legal intelligenceMarie Dean Arrington was placed in close management confinement at Broward Correctional Institution. She challenged this placement, arguing it violate…
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GLICKSTEIN, Judge.
We treat this as a petition for writ of mandamus, grant the petition and direct respondents to conduct a hearing within thirty days to determine whether petitioner should remain in close management, pursuant to rule 33-3.083(2)(a), Florida Administrative Code, and the Due Process Clause of the Fourteenth Amendment. See Parker v. Cook, 642 F. 2d 865, 867 and n. 1 (5th Cir.1981), and Wright v. Enomoto, 462 F.Supp. 397, 402 (N.D.Cal.1976), affirmed, 434 U.S. 1052, 98 S.Ct. 1223, 55 L.Ed.2d 756 (1978).
We reject petitioner’s argument that she has been denied equal protection of the law. Since we are not dealing with a suspect classification, a rational basis bearing a substantial relation to public safety for the practice of placing inmates in close confinement, is all that the State needs in order to justify it, and such an explanation is obviously available.
We also reject her claim that the classification and retention in close management status constitutes a per se cruel and inhuman punishment. Essential goals that may require limitation or retraction of a prisoner’s retained constitutional rights are maintaining and preserving internal order and discipline. Bell v. Wolfish, 441 U.S. 520, 546, 99 S.Ct. 1861, 1878, 60 L.Ed.2d 447, 473 (1979). “Prison officials must be free to take appropriate action to ensure the safety of inmates and corrections personnel and to prevent escape .... ” Id. at 547, 99 S.Ct. at 1878, 60 L.Ed.2d at 473. “Prison administrators therefore should be accorded wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security.” Id.
“Such considerations are peculiarly within the province and professional expertise of corrections officials, and, in the absence of substantial evidence in the record to indicate that the officials have exaggerated their response to these considerations, courts should ordinarily defer to their expert judgment in such matters.” Pell v. Procunier, 417 U.S. at 827, 94 S.Ct. at 2806 [41 L.Ed.2d 495 (1974)]. We further observe that, on occasion, prison administrators may be “experts” only by Act of Congress or of a state legislature. But judicial deference is accorded not merely because the administrator ordinarily will, as a matter of fact in a particular case, have a better grasp of his domain than the reviewing judge, but also because the operation of our correctional facilities is peculiarly the province of the Legislative and Executive Branches of our Government, not Judicial. Procunier v. Martinez, supra, 416 U.S. at 405, 94 S.Ct. at 1807 [40 L.Ed.2d 224 (1974)]; cf. Meachum v. Fano, supra, 427 U.S. at 229, 96 S.Ct. at 2540 [49 L.Ed.2d 451 (1976)].
Id. at 547-48, 99 S.Ct. at 1878-79, 60 L.Ed.2d at 474.
ANSTEAD, C.J., and BERANEK, J., concur.
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Armor Corr. Health Servs., Inc. v. Ault, 942 So. 2d 976 (Fla. 4th DCA 2006)…Florida Dep’t of Health & Rehab. Servs. v. Myers, 675 So. 2d 700 (Fla. 4th DCA 1996). Operation of the county jail is within the province of the executive and legislative branches of government, not the judicial branch. See Arrington v. Wainwright, 452 So. 2d 1120, 1121 (Fla. 4th DCA 1984) (citing Procunier v. Martinez, 416 U.S. 396, 405, 94 S.Ct. 1800, 40 L.Ed.2d 224 (1974), overruled on other grounds, Thornburgh v. Abbott, 490 U.S. 401, 109 S.Ct. 1874, 104 L.Ed.2d 459 (1989)). While the system devised by th…
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Ric L. Bradshaw v. Sandler, 955 So. 2d 1219 (Fla. 4th DCA 2007)…e concerning the separation of powers doctrine. There, we noted the “[ojperation of the county jail is within the province of the executive and legislative branches of government, not the judicial branch.” Id. at 977 (citing Arrington v. Wainwright, 452 So. 2d 1120, 1121 (Fla. 4th DCA 1984)). As such, “the trial court has no authority to dictate how [the private health care provider] carries out the sheriffs duty to provide medical care to jail inmates.” Id. Health care decisions of jail inmates are exclusivel…
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McQUEEN v. J.A. Tabah, 839 F.2d 1525 (11th Cir. 1988)…rty interest and that they were required to perform the duties prescribed by Reg. (6)(f)(4) to comport with due process under the Constitution. The Florida District Court of Appeal for the Fourth District had held as much in Arrington v. Wainwright, 452 So. 2d 1120 (1984). In that case, the Florida court mandated a review of a prisoner’s close management status under Reg. 33-30083(2)(a) Fla.Admin.Code and the due process clause of the Fourteenth Amendment. See also, Sims v. Adams, 537 F. 2d 829, 832 (5th Cir.1…
Authorities Cited
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979)
- Procunier v. Martinez, 416 U.S. 396 (U.S. 1974)
- Meachum v. Fano, 427 U.S. 215 (U.S. 1976)
- Pell v. Procunier, 417 U.S. 817 (U.S. 1974)
- Beer et ux. v. Commissioner of Internal Revenue, 434 U.S. 1052 (U.S. 1978)
- Parker v. Cook, 642 F.2d 865 (5th Cir. 1981)
- Enomoto v. Wright, 434 U.S. 1052 (U.S. 1978)