Johnson v. California

Johnson v. California
Supreme Court of the United States
Decided February 23, 2005
Full case nameJohnson v. California
Citations543 U.S. 499 (more)
Holding
A prison system's policy of segregating new residents by race for the purpose of inhibiting gang violence is subject to strict scrutiny analysis.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityO'Connor, joined by Kennedy, Souter, Ginsburg, Breyer
ConcurrenceGinsburg, joined by Souter, Breyer
DissentStevens
DissentThomas, joined by Scalia
Rehnquist took no part in the consideration or decision of the case.

Johnson v. California, 543 U.S. 499 (2005), was a United States Supreme Court case in which the court held that a prison system's policy of segregating new residents by race for the purpose of inhibiting gang violence is subject to strict scrutiny analysis.[1][2][3][4][5][6][7][8][9]

Background

The California Department of Corrections's (CDC) unwritten policy of racially segregating prisoners in double cells for up to 60 days each time they enter a new correctional facility is based on the asserted rationale that it prevents violence caused by racial gangs. Johnson, an African-American person who has been intermittently double-celled under the policy's terms ever since his 1987 incarceration, filed a lawsuit alleging that the policy violated his Fourteenth Amendment right to equal protection. The federal District Court granted the defendants, former CDC officials, summary judgment on grounds that they were entitled to qualified immunity. The Ninth Circuit Court of Appeals affirmed, holding that the policy's constitutionality should be reviewed under the deferential standard articulated in Turner v. Safley, not under strict scrutiny, and that the policy survived Turner scrutiny.[1]

The Supreme Court granted certiorari.[1]

Opinion of the court

The Supreme Court issued an opinion on February 23, 2005. The court said that "Prisons are dangerous places, and the special circumstances they present may justify racial classifications in some contexts." However, they determined that such a policy must satisfy strict scrutiny.[1]

Later developments

Rather than the case being reheard by the 9th Circuit, the CDC and Johnson settled the case. The CDC agreed to end its use of race as the sole determinative criterion for double-celling newly arrived prisoners.[10] Eight months after the ruling, the CDC released an "In-Cell Racial Integration Plan," which would categorize prisoners based on racial eligibility. If the prisoner was a victim or perpetrator of a racially motivated crime, they would be considered racially restricted and prevented from being housed with certain races. [11]

References

  1. 1 2 3 4 Johnson v. California, 543 U.S. 499 (2005).
  2. ↑ Robinson, Brandon (October 1, 2006). "Johnson v. California: A Grayer Shade of Brown". Duke Law Journal. 56 (1): 343–375. ISSN 0012-7086.
  3. ↑ Smith, Jacob (January 1, 2006). "Johnson v. California: The Supreme Court Invades the States' Authority to Establish Criminal Procedures". Journal of Criminal Law and Criminology. 96 (3): 995.
  4. ↑ El-Mallawany, Deana (January 1, 2006). "Johnson v. California and the Initial Assessment of Batson Claims". Fordham Law Review. 74 (6): 3333.
  5. ↑ Budnitz, Elizabeth (January 1, 2006). "Not a Part of Her Sentence: Applying the Supreme Court's Johnson v. California to Prison Abortion Policies". Brooklyn Law Review. 71 (3). ISSN 0007-2362.
  6. ↑ Grumberger, Rachel (January 1, 2006). "Johnson v. California: Setting a Constitutional Trap for Prison Officials". Maryland Law Review. 65 (1): 271. ISSN 0025-4282.
  7. ↑ Feist, Michelle (January 1, 2006). "Constitutional Law - Equal Protection of Law: Strict Scrutiny Applies to All Racially Segregated Citizens, Free and Confined". North Dakota Law Review. 82 (1): 263–296. ISSN 0029-2745.
  8. ↑ Gastwirth, Joseph L. (September 1, 2005). "Case comment: statistical tests for the analysis of data on peremptory challenges: clarifying the standard of proof needed to establish a prima facie case of discrimination in Johnson v. California". Law, Probability and Risk. 4 (3): 179–185. doi:10.1093/lpr/mgi014. ISSN 1470-840X.
  9. ↑ Robertson, James (January 1, 2006). "Foreword: Separate but Equal in Prison: Johnson v. California and Common Sense Racism". Journal of Criminal Law and Criminology. 96 (3): 795.
  10. ↑ "California DOC Settles Racially Determinative Housing Suit | Prison Legal News". www.prisonlegalnews.org. Retrieved July 12, 2026.
  11. ↑ "California Department of Corrections & Rehabilitation In-Cell Racial Integration Plan" (PDF). www.prisonlegalnews.org.

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