“In an ongoing class action initiated in 1990 by a group of California state prisoners alleging that the State of California violated the Eighth Amendment by failing to provide constitutionally adequate mental health care in its prisons, the panel affirmed the district court’s order holding the State in civil contempt, vacated the district court’s imposition of fines to the extent they exceeded the State’s monthly salary savings, and remanded. In 2017, following years of unsuccessful remedial orders and ongoing communications with the court-appointed Special Master, the district court gave the State one last year to comply with the core requirement that the State bring health care provider staffing vacancies down to fixed levels. By 2023, the State had remained far from compliant. In response, the district court established a schedule of prospective, conditional fines that would begin accumulating every month that the State failed to achieve its staffing obligations. The fines were based on the  approximate salary savings that the State achieved by failing to fill the required staffing positions. In 2024, after finding persistent noncompliance, the court issued its final contempt findings: the state’s noncompliance had resulted in the accrual of over $110 million in fines. 

 

The panel held that the district court did not err In holding the State in civil contempt of applicable staffing orders and in rejecting the State’s substantial compliance defense and its impossibility defense. The panel further held that the imposed contempt fines were civil in nature and did not require criminal due process protection. Nevertheless, the panel determined that the fines imposed by the district court were not sufficiently tethered to the record. In particular, the panel was concerned with the court’s calculation of the fines based upon a doubling of the State’s monthly salary savings. Therefore, the panel vacated the fines to the extent that they exceed the State’s monthly salary savings, and remanded to the district court for additional findings and analysis as to the exact amount of fines that should be imposed.”