Wednesday, November 6, 2013

Johnson v. California case brief

Johnson v. California case brief summary
543 U.S. 499 (2005)

Petitioner prison inmate sued respondent California Department of Corrections (CDC), alleging that the CDC's unwritten policy of segregating new and transferred prisoners by race violated the inmate's constitutional right to equal protection of the laws. Upon the grant of a writ of certiorari, the inmate appealed the judgment of the U.S. Court of Appeals for the Ninth Circuit which upheld the policy under a deferential standard.


  • Under the CDC policy, a new or transferred prisoner at a correctional facility was assigned a cellmate of the same race in a reception center pending a regular housing assignment. 
  • The CDC contended that the policy was necessary to prevent violence caused by racial prison gangs and was thus reasonably related to legitimate penological interests. 
  • The United States Supreme Court held, however, that the policy was instead subject to strict judicial scrutiny since it was based on racial classification, and thus the classification was required to be narrowly tailored to further compelling CDC interests. 
  • All racial classifications were immediately suspect and subject to strict scrutiny, and the CDC policy was no exception simply because all races were equally segregated, since the segregation itself reinforced racial and ethnic divisions in the correctional facilities. 
  • Further, the CDC's discretion and expertise in the unique area of managing daily prison operations did not warrant deference to the CDC's use of race as a means of controlling prison violence, and compromising the inmate's equal protection rights was not necessarily needed for proper prison administration.

The judgment upholding the CDC's racial segregation policy under a deferential standard was reversed, and the case was remanded for a determination of the constitutionality of the policy under the standard of strict scrutiny.

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