Ruiz v. Estelle: A Study

Ruiz v. Estelle: A Study in Needed Reform

What constitutes "cruel and unusual" punishment? The Eighth Amendment guarantees, "Excessive bail shall not be required...nor cruel and unusual punishment inflicted." (U.S. Constitution) While the debate continues today, the landmark case Ruiz v. Estelle, the question of whether certain prison conditions met the cruel and unusual element was answered with a definitive yes. This case lead to significant changes in the penal system in regards to reducing overcrowding, improving healthcare, improving security and working conditions, and reducing or eliminating severe or arbitrary disciplinary procedures. (University of Texas). A closer look at this landmark case, the history leading up to it and the reforms that came as a result gives us a clearer picture of which penal procedures and processes needed change, and why this change was so desperately needed. A number of unintended consequences stemming from this landmark decision also deserve examination, as they speak to the deeper philosophy behind our modern penal system.

David Resendez Ruiz didn't have the easiest start in life. One of 13 children of migrant workers, Ruiz had his first run-in with the law in 1954 when he was only 12 years old. (Worker's World) When his troubled teen years became a more troubled early adulthood, Ruiz was sentenced to seven years for yet another car theft. In July, 1968, he was once again sentenced for robbery by assault (Texas Monthly) and returned to the Texas Department of Corrections.

Far from a model prisoner, Ruiz admitted to stabbing, "Three to four of his fellow inmates." (Texas Monthly) A closer examination of prison conditions in Texas during the time of Ruiz' incarceration may not exonerate, but may well mitigate, his actions. During Ruiz' incarceration in the Texas Department of Corrections, he filed the civil lawsuit that would change the way prisons operated for decades by suing the director of the Texas Department of Corrections, William J. Estelle, in 1972. (University of Texas) Among other things, Ruiz asserted in his handwritten motion that conditions of dangerous overcrowding, lack of medical care, and brutal treatment of the guards violated his Eighth Amendment rights prohibiting cruel and unusual punishment.

Other inmates soon joined in the cause, turning the once simple civil action into a class action lawsuit in 1974. (McClatchy Washington Bureau). Judge William Wayne Justice, an appropriate name if ever one was in the field of law, presided over the case, declaring in 1980 that the conditions in the Texas Department of Corrections did indeed constitute cruel and unusual punishment. The case went up to appeal, but in 1999 the United States District Court of Houston, Texas, ruled that:

(1) earlier court order, relinquishing jurisdiction over question whether system for classifying prisoners was inadequate, did no preclude court from further considering adequacy of classification, following reduction in prison staff performing classification functions; (2) provision of Prison Litigation Reform Act (PLRA), terminating all court orders calling for prospective relief two years after its effective date, violated separation of powers principles of Constitution when applied to indefinite duration consent order requiring that Texas prisons be brought into conformity with constitutional requirements; (3) PLRA did not violate due process rights of prisoners; (4) PLRA did not violate equal protection rights of prisoners; (5) prison medical treatment did not violate Eighth Amendment Rights of prisoner's; (6) placement of prisoners in administrative segregation was Eighth Amendment violation; (7) prisons exhibited deliberate indifference to safety of prisoners, in violation of their Eighth Amendment rights; and (8) prisoners were subjected to excessive force, in violation of their Eighth Amendment rights.

When Ruiz v. Estelle was filed, Texas had only 18 prisons. Today, Texas boasts 112 and state jails that house approximately 160,000 inmates. (Texas Monthly)

Granted, these improvements came at a cost, both in monetary terms and in regards to controversy and public outcry. Building more prisons (only 15 of the 112 current Texas prisons are private) cost the taxpayers money, money that, given the current economic climate is begrudgingly spent. Indeed, Dick J. Reavis, of the Texas Monthly, believes that the prisons of 20 years ago were much more cost-effective, and also much more effective in their job of rehabilitation, than prisons who now operate under the guidance of the PLRA (Prison Litigation Reform Act) signed into law by President Clinton in 1995. He states the previous prison system: "was a more efficient but no less ugly system because things were that way. Texas prisons were places where, in defiance of law, prisoners were punished by assault, by kicks and blows from guards and their convict allies, the building tenders. Men were thrown into darkened cells and kept incommunicado and wasting away on a diet of bread and water." (Texas Monthly) Was this effective at keeping the peace? Reavis think so, as do many of the old guard. The old system certainly seems to address three of the four theories of why we incarcerate criminals: Refrain (keeping criminals from committing more crime), Restraint (keeping criminals away from the general public), and Retribution (making criminals pay for what they did). But what about the fourth "R" -- Rehabilitation? Is it possible for a criminal to be rehabilitated in such an environment? Or was retribution more, as "Red" says in The Shawshank Redemption, "Rehabilitation? It's just a bullshit word. So go ahead and stamp your forms, sonny, and stop wasting my time." Most criminals, Ruiz included, came from horrific backgrounds -- will more horror serve to set them straight when to them, it is just more of the same? That seems dubious psychology and theory at best, justification of torture at worst.

Certainly, the relatives of David Resendez Ruiz would believe that the latter -- rehabilitation -- is every bit as important as the former "R's" of refrain, restraint and retribution. According to Ruiz' daughter, Eva, "To me, because of his lawsuit, he has made history. He felt that everyone should be treated humanely, even though they made a mistake. To me, my dad gave his life for the prisoners." (Workers World)