Johnson v. California

543 U.S. 499 (2005)

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Nature of the Case

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Facts

D racially segregates new inmates to prevent violence caused by racial gangs. P has been incarcerated since 1987. Each time he was transferred to a new facility D was double-celled with another African-American inmate. P filed a complaint alleging D’s reception-center housing policy violated his right to equal protection under the Fourteenth Amendment by assigning him cellmates on the basis of his race. The District Court dismissed his complaint for failure to state a claim. The Court of Appeals for the Ninth Circuit reversed and remanded, holding that P had stated a claim for racial discrimination in violation of the Equal Protection Clause of the Fourteenth Amendment. On remand, P was appointed counsel and granted leave to amend his complaint. Since 1987, he has been segregated each time he has been transferred to a new facility. The District Court granted summary judgment to Ds on grounds that they were entitled to qualified immunity because their conduct was not clearly unconstitutional. The Court of Appeals for the Ninth Circuit affirmed. It held that the constitutionality of the policy should be reviewed under the deferential standard articulated in Turner v. Safley. P had the burden of refuting the “common-sense connection” between the policy and prison violence. The Court of Appeals concluded that the policy survived Turner’s deferential standard. The Supreme Court granted certiorari to decide which standard of review applies.