Rasko v. Jeffreys

Dist. Ct. erred in entering permanent injunction in plaintiff-prisoners’ class action, alleging that defendants-Illinois Dept. of Corrections officials failed to provide constitutionally adequate mental-health care. Record showed that parties eventually settled case, which required that defendants meet certain hiring and other benchmarks across more than dozen areas of mental health for prisoners. After defendant failed to reach said benchmarks, plaintiff returned to Dist. Ct. and argued, as required by settlement agreement, that defendants' failure to reach said benchmarks itself caused 8th Amendment violation. Dist. Ct. held that plaintiffs made requisite showing in five areas of mental health treatment and eventually entered permanent injunction requiring defendants to hire and maintain specific number of additional staff and imposing other requirements for delivery of mental-health on Dist. Ct.’s timetable. Ct. of Appeals, though, found that injunction had been improperly entered, where, although defendants had failed to meet benchmarks, record showed that, particularly with issue of under-staffing, defendants took reasonable efforts to add additional staff, so as to preclude finding that they had recklessly disregarded known risk for 8th Amendment purposes. Also, injunction violated Prison Litigation Reform Act by prescribing specific staffing levels and treatment timelines, which failed to go no further than necessary to correct any 8th Amendment violation. (Dissent filed.)