Murphy v. Raoul
380 F.Supp.3d 731 (2019)
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Rule of Law:
A state's practice of indefinitely incarcerating indigent individuals past their court-ordered release dates solely because they cannot afford to secure a qualifying residence violates the Equal Protection Clause of the Fourteenth Amendment and the Eighth Amendment's prohibition on cruel and unusual punishment.
Facts:
- In Illinois, individuals convicted of certain sex offenses must serve a term of Mandatory Supervised Release (MSR) after completing their prison sentence.
- A condition for beginning MSR is that the individual must secure a 'host site'—a residence approved by the Illinois Department of Corrections (IDOC).
- The IDOC imposes numerous and strict restrictions on potential host sites, including proximity to schools and parks, the presence of children, internet access, and other factors.
- Paul Murphy and a class of other plaintiffs were convicted of sex offenses, completed their court-ordered prison sentences, and were approved for release onto MSR by the Prisoner Review Board.
- The plaintiffs are indigent, lack family or financial support, and have been unable to find or afford housing that meets the IDOC's strict approval criteria.
- Transitional housing facilities and homeless shelters in Illinois do not accept individuals convicted of sex offenses.
- As a result of their inability to secure an approved host site due to their indigence, the plaintiffs have remained incarcerated for years beyond their scheduled release dates.
- Wealthier individuals in the same situation can secure an approved residence and are released to serve their MSR term in the community.
Procedural Posture:
- A class of indigent sex offenders (Plaintiffs) filed a civil rights lawsuit under 42 U.S.C. § 1983 against the Director of the Illinois Department of Corrections and the Illinois Attorney General (Defendants) in the United States District Court for the Northern District of Illinois.
- The complaint alleged that the state's host-site requirement for mandatory supervised release violated their rights under the Eighth and Fourteenth Amendments.
- The Defendants filed a motion to dismiss, arguing the claims must be brought through individual habeas corpus petitions, which the court denied.
- After discovery, both the Plaintiffs and Defendants filed cross-motions for summary judgment.
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Issue:
Does the Illinois Department of Corrections' practice of continuing to incarcerate indigent sex offenders, who have completed their prison terms and been approved for release, solely because they are unable to secure a qualifying residence violate the Eighth and Fourteenth Amendments?
Opinions:
Majority - Virginia M. Kendall
Yes, the practice violates the Equal Protection Clause of the Fourteenth Amendment and the Eighth Amendment. As applied, the host-site requirement unconstitutionally discriminates against indigent individuals based on wealth, as it results in their continued incarceration while similarly situated individuals with financial resources are released. This differential treatment based on poverty is not rationally related to the state's legitimate interest in public safety. Furthermore, the practice constitutes cruel and unusual punishment under the Eighth Amendment because it punishes the plaintiffs for their status of being indigent and homeless—a condition they are powerless to change—by subjecting them to indefinite imprisonment.
Analysis:
This decision establishes that a state's post-release supervision scheme, even if facially neutral, is unconstitutional if its practical application results in the indefinite imprisonment of individuals solely because of their indigence. It extends the principle that the criminal justice system cannot punish poverty from the context of fines-to-jail time to the conditions of release. This ruling puts pressure on correctional departments nationwide to re-evaluate policies that effectively create a two-tiered system of release based on wealth. States may now be required to either provide assistance in securing housing or develop alternative, constitutional methods for supervising indigent releasees, such as GPS monitoring for those without a fixed address.
