In Plata, the Supreme Court, in an opinion authored by Justice Anthony Kennedy, held that prisoners alleging conditions of confinement claims retain some degree of human dignity despite their lawful incarceration. Accordingly, federal courts must enforce the constitutional rights of prisoners when they are violated, even if this culminates in the release of some individuals from captivity. This is in stark contrast to previous cases where the federal courts have simply deferred to the judgment of prison administrators. Plata emphatically affirms the judiciary’s role in protecting prisoners’ rights, noting that court inaction in the face of ongoing and persistent constitutional violations cannot remain simply because of prison administrators’ protestations and despite the admittedly radical nature of the remedy being considered.
Part II of this Article briefly discusses the evolution of human dignity as a constitutional value during the course of the twentieth century. This Article will explain the philosophical development of human dignity in general terms and as it was developed by the Supreme Court, with some particular attention given the Court’s Eighth Amendment jurisprudence. Part III will discuss Plata and its underlying facts. Part IV concerns how Plata may influence the use of human dignity as a constitutional value in the years to come, specifically discussing the relationship between Plata and the troublesome 2012 decision: Florence v. Board of Chosen Freeholders. As a result of cases like Plata and Florence, the vitality of human dignity as a constitutional value today remains somewhat in flux. However, this is not to say that it is irrelevant to the Court’s decision-making process. Only as future cases are decided will commentators be able to determine which case holds greater import in the area of Eighth Amendment jurisprudence, and thus evaluate the durability of human dignity as a constitutional concern.
Recommended CitationBenjamin F. Krolikowski, Brown v. Plata: The Struggle to Harmonize Human Dignity with the Constitution, 33 Pace L. Rev. 1255 (2013)
Available at: http://digitalcommons.pace.edu/plr/vol33/iss3/9