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Sixth Circuit Upholds $385,000 Contempt Sanction Against Michigan DOC
Prison officials were fined $38500, at a rate of $500 a day, for failure to provide programming to female prisoners equivalent to that for male prisoners, as required by its prior orders.
The imposition of contempt sanctions is reviewed for abuse of discretion, with factual findings reviewed for clear error. Neither is present here. The sanction "was not intended as compensatory damages, but as a punitive measure" intended to force compliance (and the court notes it seems to have worked). At 313: ". . . [I]n light of the Department's years of noncompliance," the sanctions were "remarkably forbearant. The amount in question seems at last to have succeeded in capturing the Department's attention."
At 313:
Since the purpose of the sanctions was to produce Appellants' compliance with the district court's lawful order, their nature was clearly coercive, rather than compensatory. Appellants' contention that the amount is inappropriate because it fails to match a demonstrated loss by Appellees is therefore misplaced.... The State's recalcitrance, not the prisoners' damage, is what validates the sanction amount in this case.
The district court's intention to use the money by placing it in a fund for the women's benefit is proper; the court suggests that it be used to defray the future costs of the vocational programs required by the court's orders, and not to reimburse it for past costs or for general overhead. See: Glover v. Johnson, 199 F.3d 301 (6th Cir. 1999).
The imposition of contempt sanctions is reviewed for abuse of discretion, with factual findings reviewed for clear error. Neither is present here. The sanction "was not intended as compensatory damages, but as a punitive measure" intended to force compliance (and the court notes it seems to have worked). At 313: ". . . [I]n light of the Department's years of noncompliance," the sanctions were "remarkably forbearant. The amount in question seems at last to have succeeded in capturing the Department's attention."
At 313:
Since the purpose of the sanctions was to produce Appellants' compliance with the district court's lawful order, their nature was clearly coercive, rather than compensatory. Appellants' contention that the amount is inappropriate because it fails to match a demonstrated loss by Appellees is therefore misplaced.... The State's recalcitrance, not the prisoners' damage, is what validates the sanction amount in this case.
The district court's intention to use the money by placing it in a fund for the women's benefit is proper; the court suggests that it be used to defray the future costs of the vocational programs required by the court's orders, and not to reimburse it for past costs or for general overhead. See: Glover v. Johnson, 199 F.3d 301 (6th Cir. 1999).
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Related legal case
Glover v. Johnson
| Year | 1999 |
|---|---|
| Cite | 199 F.3d 301 (6th Cir. 1999) |
| Level | Court of Appeals |
| Injunction Status | N/A |