Walker v. State

Montana Supreme Court
316 Mont. 103, 2003 MT 134, 68 P.3d 872 (2003)

ELI5:

Rule of Law:

The cruel and unusual punishment prohibitions of the Eighth Amendment and Article II, Section 22 of the Montana Constitution, when read in conjunction with Montana's inviolable right to human dignity (Article II, Section 4), are violated when prison behavior management plans and living conditions exacerbate an inmate's serious mental health condition, crossing into the realm of psychological torture.

Facts:

In December 1994, Mark Edward Walker was charged in Cascade County with felony forgery, arson, and criminal mischief; he later pleaded guilty to negligent arson and felony forgery in July 1995.
In December 1995, the District Court sentenced Walker to five years with the Department of Corrections, with all five years suspended.
While incarcerated in Colorado in 1998, Walker was diagnosed with Bipolar Disorder and was successfully treated with Lithium, which stabilized his mood and behavior.
Walker was transferred to the Montana State Prison (MSP) on February 5, 1999, where he reported his Bipolar diagnosis and Lithium regimen, but soon stopped taking his medication due to stomach pains, after which his behavior progressively declined.
Between August 1999 and March 2000, MSP officials placed Walker on five separate Behavior Management Plans (BMPs) in the A-block, a disciplinary detention unit with bare necessities, no natural light, and restricted recreation.
Under these BMPs, Walker was stripped naked, deprived of bedding and a pillow, had water access restricted, and received 'finger food' placed on a dirty slot, often for multiple days, exceeding the intended 24-48 hour duration.
Walker's behavior worsened while on BMPs, leading to increased disciplinary infractions and multiple suicide attempts (including swallowing a staple, and trying to hang himself with a sheet and coveralls).
Psychological experts testified that Walker clearly suffered from Bipolar Disorder, MSP's diagnosis was 'preposterous,' and the BMPs were 'counter-therapeutic, punitive and cruel,' exacerbating his mental illness, while MSP officials focused on discipline rather than treatment.

Procedural Posture:

On December 13, 1994, Mark Edward Walker was charged in Cascade County with felony forgery, arson, and two counts of criminal mischief.
On July 25, 1995, Walker pleaded guilty to negligent arson and felony forgery in the District Court for the Eighth Judicial District, Cascade County.
On December 18, 1995, the District Court sentenced Walker to five years with the Department of Corrections, with all five years suspended.
The State filed a petition to revoke Walker’s suspended sentence after he violated probation terms.
On December 8, 1998, after a hearing, the District Court revoked Walker's suspended sentence and resentenced him to five years with the Department of Corrections.
In January 2000, Walker, pro se, filed a petition with the Supreme Court of Montana, alleging cruel and unusual punishment by MSP officials.
On March 9, 2000, the Supreme Court of Montana treated Walker’s petition as a Writ of Mandamus, remanded the case to the Eighth Judicial District Court, and ordered that counsel be appointed for Walker.
On March 24, 2000, appointed counsel Eric Olson filed a Petition for Postconviction Relief on Walker’s behalf in the Eighth Judicial District Court, alleging sentencing irregularities.
On May 26, 2000, Olson also filed a Petition for Extraordinary Relief in the Supreme Court of Montana, alleging cruel and unusual punishment by MSP.
The two cases (postconviction and extraordinary relief) were consolidated into one postconviction proceeding in the Eighth Judicial District Court.
The Department of Corrections moved the District Court to disregard Walker’s claims about conditions of confinement, arguing they were inappropriate for postconviction relief, but the District Court denied this request.
The District Court heard testimony on ten separate days in August, September, and October 2000.
On February 14, 2001, the District Court issued its Findings of Fact, Conclusions of Law and Order, denying all relief requested by Walker, determining he had not met his burden of proof and was not subjected to cruel and unusual punishment under either the Eighth Amendment or Article II, Section 22 of the Montana Constitution.
Walker appealed the District Court’s decision to the Supreme Court of Montana, challenging the conclusion that BMPs and A-block conditions did not constitute cruel and unusual punishment.
The State moved to dismiss Walker's appeal as moot because he had been released from custody, but the Supreme Court of Montana initially denied the motion as premature, "without prejudice to the State's right to renew its motion."

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the Montana State Prison's use of Behavior Management Plans (BMPs) and the living conditions in its administrative segregation unit constitute cruel and unusual punishment under the Eighth Amendment to the United States Constitution and Article II, Sections 4 and 22 of the Montana Constitution, when these practices exacerbate an inmate’s serious mental health condition?

Opinions:

Majority - Justice Nelson

Yes, the Montana State Prison's use of Behavior Management Plans and the living conditions in its administrative segregation unit constitute cruel and unusual punishment because these practices exacerbate an inmate’s serious mental health condition, violating both the Eighth Amendment and Montana's constitutional rights to dignity and freedom from cruel and unusual punishment. The Court first addresses mootness, holding that Walker’s appeal is not moot despite his release from custody, because the case involves fundamental constitutional questions that are "capable of repetition, yet evading review" due to the short-term nature of BMPs and the continued use of such plans with mentally ill inmates. The Court also declined to address the State's argument that postconviction relief was an inappropriate proceeding because the State failed to file a cross-appeal. Turning to the merits, the Court concludes that MSP's treatment of Walker amounted to cruel and unusual punishment. Applying the "deliberate indifference test" from Farmer v. Brennan and Madrid v. Gomez, the Court finds that MSP officials were deliberately indifferent to Walker's serious mental health needs. Expert testimony established that Walker suffered from Bipolar Disorder, was neglected by MSP, which failed to provide adequate treatment, discontinued his effective medication, and imposed punitive BMPs that worsened his condition. The BMPs, which involved stripping him naked, denying bedding, restricting water, and serving unsanitary food in a harsh A-block environment, were "counter-therapeutic" and failed to prevent dangerous behavior or suicide attempts. Crucially, the Court emphasizes the broader protections of the Montana Constitution. It reads Article II, Section 22 (cruel and unusual punishment) in conjunction with Article II, Section 4 (individual dignity) to provide greater protection than the federal Eighth Amendment. The "inviolable dignity of the human being" means that correctional practices that degrade or demean persons, especially mentally ill inmates who rely on the prison for care, are forbidden. Such conditions, if they inflict serious mental illness, greatly exacerbate mental illness, or deprive inmates of sanity, "cross into the realm of psychological torture." The Court holds that BMPs and A-block conditions, as applied to Walker, affront human dignity and constitute cruel and unusual punishment due to the exacerbation of his mental health condition, reversing the District Court's decision and remanding for institutional reform.

Dissenting - Chief Justice Gray

No, the appeal should be dismissed because the case is moot, and even if not, the District Court's findings should have been affirmed as not clearly erroneous, and the Court's reliance on the Montana Constitution's dignity clause is misplaced. Chief Justice Gray argues that Walker's appeal is moot because he has been released from custody, meaning the Court cannot grant him effective relief. The "capable of repetition, yet evading review" exception should not apply because the determination of whether a BMP exacerbates an inmate's mental health condition is fact-specific to each individual case, not a broad constitutional issue like those in K.G.F. or N.B. The Chief Justice also criticizes the Court's procedural handling, particularly its sua sponte expansion of the issues to include "living conditions on A-block" and its failure to address the proper remedy for civil rights violations in prison (42 U.S.C. § 1983) instead of mandating appointed counsel through a postconviction proceeding. Furthermore, the dissent contends that the majority disregarded the District Court's extensive 56 findings of fact and conclusions of law without determining any of them to be clearly erroneous or incorrect. Many of the facts presented by the majority are at odds with the District Court's findings. Finally, Chief Justice Gray argues that the Court's reliance on Article II, Section 4 (dignity clause) is inappropriate. Walker did not properly raise this argument in the District Court, and the Court's interpretation of the clause is vague, conclusory, and lacks an analytical structure. Citing the Montana Constitutional Convention transcripts, the dissent asserts that the dignity clause was intended specifically to prohibit discrimination based on factors like race, sex, or social origin, not as a general, free-standing right applicable to conditions of confinement. The dissent fears the majority's decision will lead to skyrocketing costs and an unmanageable caseload for district courts.

Analysis:

This case significantly broadens the scope of "cruel and unusual punishment" in Montana by explicitly incorporating the state constitution's "inviolable human dignity" clause (Article II, Section 4) into the analysis of prisoner treatment. This unique interpretation provides a potentially higher standard of protection for inmates, particularly those with mental illness, than the federal Eighth Amendment alone. Future cases in Montana will need to consider how prison practices affect an inmate's "core humanity" and whether they "degrade or demean" individuals, going beyond mere physical harm or "deliberate indifference" to medical needs. The ruling could mandate more rigorous mental health screening, treatment protocols, and humane conditions in correctional facilities within Montana, especially concerning disciplinary measures like segregation and behavior modification programs, and it places district courts in an oversight role for institutional reform.

🤖 Gunnerbot:

Query Walker v. State (2003) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.

Subscribe to Lexplug to chat with the Gunnerbot about this case.

Premium Feature