Parsons v. Ryan

Inmates alleging Eighth Amendment violations satisfy the class certification requirements pursuant to Federal Rule of Civil Procedure 23, which, in turn, allows the putative class and subclass to seek injunctive and declaratory relief as an appropriate remedy.

On March 2012, inmates at the Arizona prison system (“plaintiffs”) filed suit, alleging that senior officials of the Arizona Department of Corrections (“ADC”) violated their Eighth Amendment rights through policies and practices that deliberately disregarded health care and isolation unit conditions, which thereby exposed them to significant physical and mental harm. The plaintiffs sought injunctive and declaratory relief, providing numerous discovery materials and expert reports to support their factual allegations. The district court ruled that the standard of Federal Rule of Civil Procedure 23 for class certification was met, and certified a class of inmates challenging ADC practices and policies as it pertains to health care, as well as a subclass of inmates contesting ADC isolation policies and practices. The ADC appealed, arguing that the plaintiffs failed to show commonality and typicality as required by Rule 23(a)(2) and Rule 23(a)(3) respectively, and that the district court abused its discretion in finding that injunctive relief is applicable to the class and subclass under Rule 23(b)(2). On review, the Ninth Circuit concluded that the district court did not abuse its discretion in determining that the plaintiffs satisfied the class certification requirements pursuant to Rule 23. The panel determined that both in the case of the health care and isolation confinement allegations the commonality under Rule 23(a)(2) is present because all inmates are potentially exposed to “substantial risk of serious harm.” Further, the panel determined that the plaintiffs satisfied the requirement under Rule 23(a)(3) by establishing that ADC practices and policies pose a substantial risk of harm to them and to all other member of the putative class. Therefore, the district court did not err in finding that injunctive and declaratory relief under Rule 23(b)(2) is appropriate because the relief sought by the plaintiffs would be applicable to the entire class. AFFIRMED.