In a case between Brown Governor of California, et al. v Plata et al. filed in 2001. The state admitted that inadequacies in prison medical care infringed Eighth Amendment rights of a prisoner. During the case, it was argued that, California’s prisons had an excessive population. The prisons which are meant to hold 80,000 prisoners at a time was almost double full. Hence the state required a remedial injunction. By 2005, the state had not conformed to the injunction, forcing the court to appoint a Receiver to supervise remedial efforts.
However, three years on, the Receiver insisted persistence deficiencies due to congestion. Believing that a remedy for illegal medical and mental wellness could not be attained without managing congestion, the Brown v Plata petitioners moved to their relevant District Courts to summon a three judge court influenced by the prison Litigation Reform Act 1995 (PLRA) to mandate reduction in population in prisons. In both cases, the judges conceded to the request, leading to the cases being consolidated to a single three judge court. On hearing evidence and making comprehensive findings of facts, the judges ordered that California state government reduce prison population by 137.5 percent of the intended capacity in a span of two years. Discovering that the prison could not expand its capacity through new developments, the court ordered California government to establish a compliance plan and submit it for approval by the court.

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Ultimately, it was held that, the court necessitated population limit as critical to remedy the violation of constitutional rights of prisoners as authorized by the PLRA. In addition, it held that, if prison denies prisoners of basic requirements such as adequate medical care, it is the responsibility of the court to remedy the resulting violation of the Eighth Amendment.