502us2$26D 01-22-99 08:32:58 PAGES OPINPGT
390
RUFO v. INMATES OF SUFFOLK COUNTY JAIL
Opinion of the Court
“would necessarily imply that the only legally enforceable obligation assumed by the state under the consent
decree was that of ultimately achieving minimal constitutional prison standards. . . . Substantively, this would
do violence to the obvious intention of the parties that
the decretal obligations assumed by the state were not
confined to meeting minimal constitutional requirements. Procedurally, it would make necessary, as this
case illustrates, a constitutional decision every time an
effort was made either to enforce or modify the decree
by judicial action.” Plyler v. Evatt, 924 F. 2d 1321, 1327
(CA4 1991).
While a decision that clarifies the law will not, in and of
itself, provide a basis for modifying a decree, it could constitute a change in circumstances that would support modification if the parties had based their agreement on a misunderstanding of the governing law. For instance, in Pasadena
City Bd. of Ed. v. Spangler, 427 U. S. 424, 437–438 (1976), we
held that a modification should have been ordered when the
parties had interpreted an ambiguous equitable decree in a
manner contrary to the District Court’s ultimate interpretation and the District Court’s interpretation was contrary to
intervening decisional law. And in Nelson v. Collins, 659
F. 2d 420, 428–429 (1981) (en banc), the Fourth Circuit vacated an equitable order that was based on the assumption
that double bunking of prisoners was per se unconstitutional.
Thus, if the sheriff and commissioner could establish on
remand that the parties to the consent decree believed that
single celling of pretrial detainees was mandated by the Constitution, this misunderstanding of the law could form a basis
for modification. In this connection, we note again, see
supra, at 375, that the decree itself recited that it “sets forth
a program which is both constitutionally adequate and constitutionally required.” (Emphasis added.)
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