User:Ahavriliak/sandbox

Possible Articles to Edit for Project:

https://en.wikipedia.org/wiki/Cramer_v._United_States


 * facts need work (historical context)
 * analysis of the majority opinion needs elaboration

https://en.wikipedia.org/wiki/Bell_v._Wolfish


 * both facts and discussion of the opinion/reasoning need a lot of elaboration

Edits to be considered/made to the Bell v. Wolfish page:


 * Current text of holding section : "Bell v. Wolfish, 441 U.S. 520 (1979), is a case in which the United States Supreme Court found that it was not a violation of the Fourth Amendment to perform intrusive body searches on pre-trial detainees"
 * There is a single citation provided for this sentence: https://biotech.law.lsu.edu/cphl/articles/hastings/hastings-2_-3.htm


 * Issues ident ified :
 * This is a very basic summary of the holding. I'd like to (1) verify the sentence and (2) add two to three sentences of depth (perhaps distinguishing majority versus dissent reasoning, or explaining the rationale for the holding).
 * I'm also a bit dubious about the source provided in the single citation to the holding summary. I'd like to try and find an additional source to cite for the holding information.
 * In general, there is a lot more that could be added to the page, but I will try to keep my edits as minimal and targeted as possible to avoid introducing errors.

Potential sources for the edits to Bell v. Wolfish page:


 * Francis S. Coles, The Impact of Bell v. Wolfish on Prisoners' Rights, 10 J. Crime & Justice 47 (1987).


 * Keith A. Hassler, Case Comment: Bell v. Wolfish: The Rights of Pretrial Detainees, 6 New England J. on Prison Law, 129 (1979).


 * Jonathan R. Haden, Constitutional Law: Bell v. Wolfish - A Balk at Constitutional Protection for Pretrial Detainees, 48 UMKC L. Rev. 466 (1980).


 * James Brian Boyle, Constitutional Law--Pretrial Detention--Due Process--Bell v. Wolfish (Comment), 26 N.Y. L. Sch. L. Rev. 341 (1981).

Draft Edits: <> indicate added text

Current Text of Lead section of Article as of 5/10/18:"Bell v. Wolfish, 441 U.S. 520 (1979), is a case in which the United States Supreme Court found that it was not a violation of the Fourth Amendment to perform intrusive body searches on pre-trial detainees."Draft Edits (5/11/18):"Bell v. Wolfish, 441 U.S. 520 (1979), is a case in which the United States Supreme Court found that treatment of pre-trial detainees is subject to constraint by the First, Fifth, and Fourteenth Amendments. The Court held that the challenged practice of “double-bunking” pretrial detainees did not violate the due process clause of the Fifth Amendment. The Court also determined that the policy of prohibiting detainees from receiving hard-cover books not mailed directly from the publisher did not violate the First Amendment. In addition, the Court held that the practice of prohibiting detainees from receiving packages from outside the facility was not a due process violation under the Fifth Amendment. Nor, in the Court’s opinion, was the practice of performing body cavity searches on detainees after contact visits a violation of the Fourth Amendment. Finally, the Court held that none of these practices constituted punishment within the meaning of the Fifth Amendment." --> These edits were added to the lead paragraph on 5/18/18.

Potential Edits to Factual Summary and Significance paragraphs:

Current Significance Paragraph (there is no Factual Summary) as of 5/18/18:"This case arose as a challenge to the conditions under which pretrial defendants are confined. The petitioners claimed that in the absence of a conviction, subjecting incarcerated defendants automatically to the same conditions as convicted felons was unconstitutional punishment. The federal district court agreed with this view, holding that defendants could only be deprived of liberty as a matter of 'compelling necessity'. It was also determined that The Supreme Court felt that the possible innocence of pre-trial detainees should not prevent corrections officials from taking necessary steps to maintain their facility."Draft Edits:


 * 1) Change title of subsection "Significance"  to "Factual Background and Procedural Posture"
 * 2) Make first sentence more precise: This case arose as a challenge to the conditions under which pretrial defendants are confined.>>> Inmates at the Metropolitan Correctional Facility (MCC), a federal short-term detention facility in New York City, filed a class action suit challenging the constitutionality of several conditions of their confinement.
 * 3) Adjust additional sentences for accuracy.    Factual Background and Procedural Posture :  Inmates at the Metropolitan Correctional Facility (MCC) filed a class action suit challenging the constitutionality of several conditions of their confinement. Constructed in 1975 in New York City, the MCC served as federally-operated short-term detention facility for defendants awaiting trial at one of three federal district courts located in the New York City area. Though the MCC was initially constructed to house some 449 inmates, administrators were quickly forced to double-bunk inmates to accommodate the "unprecedented" increase in new detainees. In their complaint, petitioners argued that this practice of double-bunking inmates awaiting trial was unconstitutional. They also made claims against various MCC policies, including the "undue length of confinement, improper searches, inadequate recreational, educational, and employment opportunities, insufficient staff, and objectionable restrictions on the purchase and receipt of personal items and books." After certifying the case as a class action, the U.S. District Court for the Southern District of New York enjoined the MCC practices challenged by petitioners, holding that defendants could only be deprived of liberty as a matter of "compelling necessity." On appeal, the U.S. Court of Appeals for the Second Circuit affirmed nearly all of the District Court's rulings, including the due process standard the District Court utilized in enjoining the MCC's practices. The Court of Appeals did not affirm the District Court's Eighth Amendment analysis related to convicted inmates at the MCC awaiting sentencing or transfer, and instead remanded that issue to the District Court.