Larry Meachum et. al., Petitioners, v. Arthur Fano:
What Happened and What Does it Mean?
Jackie Phillips
Criminology, Post University
CRJ335 Prisoner’s Rights Case Study Assignment 2
Prof T Johnson
Due: 11:59 pm Sunday of Unit
A case study brief includes a summary of the facts; identification of the legal issue; and a summary of the holding of the court. The holding is the essential part of the decision and the rationale behind the decision. The case for this week is:
Larry Meachum et. al., Petitioners, v. Arthur Fano, et. al.
427 U.S. 215 (96 S.Ct. 2532, 49L.Ed.2d 451)
- Title and Citation
Title:
Who is opposing whom? The name of the person who initiated legal action will appear first.
Larry MEACHUM
Arthur FANO
Citation:
How to locate the case. Includes the # of the volume where the case is located, the specific court, specific page #, and the year when the Court issued the decision.
Supreme Court
427 U.S. 215
96 S.Ct. 2532
49 L.Ed.2d 451
Argued April 21, 1976.
Decided June 25, 1976.
Rehearing Denied Oct. 4, 1976. See 429 US 873, 97 S.Ct. 191.
- Facts of the Case
A one-sentence description of the nature of the case
The plaintiff, a prisoner, was complaining about the conditions of the prison that he was transferred to after a fire broke out in the prison he was originally sentenced to.
A statement of the relevant law, with quotation marks or underlining to draw attention to the key words or phrases that are in dispute.
The 14th Amendment is being cited and whether the Due Process Clause allows for a hearing before a prisoner is transferred to another prison.
A summary of the complaint (in a civil case) plus relevant evidence and arguments presented in court to explain who did what to whom and why the case was thought to involve illegal conduct.
The complaint was that the prison that he was transferred to was less favorable to the one that he was originally sent to after his criminal conviction.
The inmate said that the prison he was transferred to was less than where he was at because of fires at the original plant. The recommendations were based on fires that were at the prison and that the complaint was thought to have been involved in the setting of the fires.
The complaint was based on that the prison they were transferred to was intentionally done to further punish the prisoner.
A summary of actions taken by the lower courts, for example: defendant convicted; conviction upheld by appellate court; Supreme Court granted certiorari.
In District court Wolf vs. McMcDonnell, the decision was made in favor of the prison in a similar case.
- Issues
What is the question that is facing the court?
The question is whether it is fair to transfer a prisoner to another prison due to circumstances at the current prison, and whether that transfer interferes with the prisoner’s Due Process Clause of the 14th Amendment.
- Decisions
How did the court answer the issue questions?
The court decided that there was no violation of the plaintiff’s Due Process rights to transfer him to another prison. It said that the prisoner is not scheduled to be in one specific prison for the time of their imprisonment and the state is not breaking the 14th Amendment to transfer the prisoner to another prison if that is needed from inside the prison.
- Rationale
Why did the court decide the way it did? What legal reasoning informed the court’s decision?
The court found that there was no reason that the inmate could say that transferring them to another prison was against their Due Process rights. The court felt that the state has the right to transfer inmates as needed to different prisons, and the inmate is not guaranteed to stay in only the original prison they were sentenced to.
- Separate Opinions:
Concurring or Dissenting:
The Court of Appeals agreed with the courts decision that the inmates do not have a guarantee that they will remain in the same original prison that they are first sent to. They agreed that the state has the right to transfer inmates as needed to maintain safety and control, and for other reasons that the prison officials need to maintain.
- Analysis: Evaluate the significance of the case.
What is important about this decision? Is the argument sound? What are the possible implications of this decision?
I think it is a sound decision for the courts to state and reaffirm that they have the right to move prisoners around as needed to maintain safety and control. As the prison population grows and decreases in each state, prison officials need to maintain the right to keep order and safety inside the prison as they see fit.
How does it fit with previous decisions? Its relationship to other cases? Its place in history?
I think it shows that the courts are willing to hear the case by the prisoner and to consider their complaints and concerns. I think it shows that the courts are also willing to listen to the needs of the prison. Since this case goes all the way back to 1976, I would like to know about any current decisions since this case. I found current cases for the 14th Amendment, but not one that matches this case.
What does this case show about the Court? Its members? Its decision-making processes? Impact it has on litigants, government or society?
I think this case shows that the courts are willing to uphold the position of the prison officials and their needs to keep prisons safe for all, both inmates and employees. It shows that the courts are willing to listen to the complaints of inmates and to give them the chance to express their concerns.
References
No author given, 1976, Cornell Law School, Larry MEACHUM et al., Petitioners, v. Arthur FANO et al., https://www.law.cornell.edu/supremecourt/text/427/215
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