Prison Phone Justice

Case: 1:17-cv-00652-SJD Doc #: 14 Filed: 11/30/17 Page: 1 of 23 PAGEID #: 137

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION

SAMUEL ROBINSON, MARKALO HARRIS
ERIC BUIG, JASON ROBINSON, GREGORY WILSON,
DONTONYIO SPRUILL, DEMETRIOUS RUFF, BRANDON
EUBANK, WILLIAM DABNEY, MATTHEW LOUTHAN,
ROBERT FELLER, ROBERT LYLES, MIKE MAXWELL, SHAWN
HARRISON, DEMARCO JENKINS, CECIL JOHNSON,

AND NATHAN BAINUM, THOMAS DIEHL, MARK CORDELL,
BRANDON DILTS, WILLIAM HUGHES, MARK WHITSON,
MICHAEL WALLS, DERRICK JACKSON, DAVENO BROWN,
IREESE KENNEDY, AARON BEMMES, ROBERT MILLER, DANIEL
JOHNSON, MICHAEL MILLER, JOSEPH MCCLURE, AND
NICOLAS SIMMONS
on behalf of themselves
and a class of others similarly

Second Amended
Class Action Complaint
and Jury Demand

situated,
Plaintiffs,

CASE NO. 17-652

SHERIFF JIM NEIL, individually and
In his capacity as Sheriff of Hamilton
County Ohio
Defendant

Introduction
1. This is an action pursuant to 42 U.S.C. 51983 challenging the overcrowded
conditions endured by detainees at the Hamilton County Justice Center.

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2. This Court has jurisdiction pursuant to 28 U.S.C. 51331, and venue is proper
under 28 U.S.C 51391 (b) as the Defendant is situated in this judicial district.
Parties
3.

Plaintiff Samuel Robinson is presently an inmate of the Hamilton County Justice
Center. He is serving a 180-day sentence from the Hamilton County Court of
Common Pleas on a conviction of a drug possession charge.
4.Plaintiffs Markelo Harris, Eric Buig, Jason Robinson, Gregory Wilson, Dontonyio

Spruill, Demetrious Ruff, Brandon Eubank, William Dabney, Matthew Louthan,
Robert Feller, Robert Lyles, Mike Marshall, Shawn Harrison, DeMarco Jenkins,

Cecil Johnson, and Nathan Bainum, Thomas Diehl, Mark Cordell, Brandon
Dilts, DeVonte Banks, William Hughes, Mark Whitson, Michael Walls,
Derrick Jackson, Daveno Brown, Ireese Kennedy, Aaron Bemmes, Robert
Miller, Daniel Johnson, Michael Miller, Joseph McClure, and Nicolas
Simmons are presently inmates in the Hamilton County Justice Center.
4. Defendant Jim Neil is the Sheriff of Hamilton County. In that capacity Defendant
Neil is responsible for the Hamilton County Justice Center including the care and
treatment of inmates detained in that facility. He has the final policymaking
authority over the jail for the actions at issue in this complaint. He is responsible
for ensuring that the policies and practices of the Justice Center comply with
Constitutional requirements for the treatment of jail detainees. Sheriff Neil is sued
in his official and individual capacities for the challenged conditions of
confinement.

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Statement of Facts
5. Samuel Robinson suffers from Osteonecrosis (Avascular Necrosis) a disease that
develops as a consequence of the loss of blood supply to the bone which causes
the bone to die. If the affected bone is near a joint, the joint surface can collapse.
As osteonecrosis progresses the pain that is associated with it limits range of
motion and becomes disabling.
6. Samuel Robinson for some number of years has had this disease. He is disabled
by it and is in constant pain. Simple movements such as getting out of bed,

sitting or bending down are painful and without proper medication are
excruciatingly painful.
7. Samuel Robinson was charged with possession of cocaine in an amount that

was less than 5 grams in violation of R.C. 2925.11 (A) and was convicted
on 6/28/ 2017 and given a sentence of 180 days in the Hamilton County
Justice Center.
8. Mr. Robinson entered the Hamilton County Justice Center on 8/4/ 2017 and

on
8/9/2017 was assigned to Pod South 21 (S21).
9. Because of the overcrowding of the Hamilton County Justice Center Mr.

Robinson was assigned to a "boat" for sleeping purposes and not assigned to
a cell with a bunk.
10. The "boats" are casket-like plastic shells that are placed on the floor in the middle
of the pods where newly admitted inmates must sleep until a cell becomes

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available after inmate turnover. New inmate admittees can sleep on the floor for
weeks waiting for an available cell. A pod often is cluttered with much of its floor
space covered by "boats.'
11. During the relevant time there were, on average, approximately seven to ten boats
in Robinson's pod. Mr. Robinson believes that this is typical of the number of
boats used in many other pods at the justice Center.
12. Inmates sleeping in boats have access only to a single toilet in one cell

during the hours of "lights out." "Lights out" in the pod area is only the
dimming of the large bank of lights that ring the ceiling of the pod.
13. Inmates, including Plaintiffs, suffer from sleep deprivation as a result of

having to be in "boats" during the night hours.
14. Mr. Robinson has witnessed as many as seven "boats" on the floor of the

pod at one time.
15. The crowding of the floor of the pods has resulted in violent encounters

between inmates and guards. Mr. Robinson witnessed one such violent
encounter between a guard and an inmate that resulted in the inmate being
handcuffed and taken to solitary.
16. On June 14, 2017 the Sheriff of Hamilton County announced a state of

emergency at the Hamilton County Justice Center due to jail overcrowding.
In a memo to Commissioner Portune, the Sheriff stated:
For approximately a year now I have been warning all county agencies of the
disturbing and unsustainable upward trend of our inmate population count at
the jail. As the Commanders pointed out in their letter to me (attached) we

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reached a boiling point this week. I cannot and will not jeopardize the safety
of my Deputies and subject them to an ongoing volatile, dangerous
environment in our jail. Nor will I put the inmates, medical staff and others
in harm's way.
. Your own County Risk Management, as well as the Hamilton County
Prosecutor's Office and State Jail Inspectors all concur we are now well outside of
acceptable practices at the jail.
17. The Jail houses inmates that now exceed twice its design capacity. A significant
consequence of this jail overcrowding is the need to use the "boats" and the unsafe
conditions resulting therefrom.
18. The Court and Jail Services Division Commander of the Sheriff's office has

determined that, "We can no longer manage a safe environment for both our
staff and inmate population.'
19. The above characterization by the Division Commander remains today.
20. When Mr. Robinson was advised by the Sheriff Deputy on S42 that he would have
to sleep in a "boat," Mr. Robinson stated that he could not " get down and back
up" out of the boat because of his disease. Mr. Robinson inquired of the Deputy
when a cell would become available and the Deputy replied that he had no idea,
but would ask his supervisor. When he was finally informed that there was no cell
available and that he was assigned to a "boat." Mr. Robinson again protested, and
as a result he was sent to solitary confinement as a punishment.
21. Solitary confinement consists of being confined in a cell for 23 hours a day with
no phone privileges, no T.V. no access to the library, and disciplinary food —a
disciplinary burger, known as a "DBU" which is inedible.

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22. Mr. Robinson was in solitary until 8/9/2017. He was unable to eat his

entirely unpalatable DBU during that time.
23. On 8/9/2107 Mr. Robinson filed a grievance, Exhibit A, which stated "I have
advascular sclerosis (sic) which is a bone disease. I am unable to get off the floor
easy and the officer on second shift made me go to the hole instead of giving me
the medical attention that I needed. I don't know the officer's name but I was on
S21 when this occurred. On top of that they served me DBU's. I have high blood
pressure and high chloresterol" (sic).
24. On 8/29/2017, not having a response to his grievance of 8/9/2017, filed a

grievance that stated, in part, . I didn't get a response from my last grievance
from being punish (sic) for my health conditions. I would like to here (sic)
a response from this grievance... " (Ex. B)
25. Again not having a response to his 8/9/2017 grievance, Mr. Robinson filed

a third grievance on 9/13/ 2017 stating "I would like a response or copy of
my grievance date submitted on 8/9/17 for being punished for my health
conditions... " (Ex. C).
26. On 8/25/ 2017 a motion was filed on Mr. Robinson's behalf in the Hamilton
County Court of Common Pleas seeking to mitigate his sentence. (Ex. D).
Attached to the memorandum in support of the motion were medical records
indicating that Mr. Robinson's diagnosis included, "CHRONIC PAIN
SYNDROME, AVASCULAR NECROSIS (HCC) CHRONIC PAIN OF BOTH

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SHOULDERS, CHRONIC PAIN OF BOTH ANKLES, BILATERAL HIP PAIN,
and KNEE EFFUSION, LEFT."
27. The motion was denied by Judge Jerome Metz. On 9/8/2017 a lawyer was

appointed for the purpose of an appeal.
28. Mr. Robinson remains in the Hamilton County Justice Center with an

outdate of 1/19/2018.
29. Mr. Robinson will continue to reside in an unsafe and violent environment until
his discharge from the jail.
30. To avoid violent encounters Mr. Robinson confines himself to his cell practically
all day and night.
31. All Plaintiffs have suffered similar Constitutional injuries due to the jail
overcrowding, including: having to sleep in boats on the floors of the pods in
lighted and cold conditions at night making sleep difficult to impossible; being
prey to having personal items stolen because of no secure place to store things like
toothbrushes; having to wear jail clothing for up to two weeks without a change;
not getting daily exercise because of staff shortages; being subjected to intense
noise throughout the day; experiencing constant altercations and physical fights
because of the oppressive proximity to other inmates; having limited phone access
because of the phone demand by more inmates that the design capacity; having
sporadic and delayed access to medical care; having occasional shortages of food;
and having sporadic shortages of blankets and sheets.

Class Action Allegations

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32. All 33 Plaintiffs bring this action on their behalf and on behalf of a class of those
similarly situated pursuant to Rule 23 (b)(2) of the Federal Rules of Civil
Procedure.
33. Plaintiffs seek to represent a class consisting of all inmates of the Hamilton
County Justice Center since October 2015.
34. Plaintiffs estimate that in that two year period there were over 5,000 persons

detained at the Hamilton County Justice Center.
35. Common questions of law and fact exist as to all class members. Among the
common questions are:
a. whether the conditions of confinement in an overcrowded jail violate

class members' rights under the Eighth and Fourteenth Amendment to
the United States Constitution by subjecting them conditions of
confinement that subject each of them to imminent risk of physical
and psychological harm ;
b. whether the Hamilton County Sheriff, Jim Neil, and Hamilton County

maintain a policy, custom and/ or widespread practice of violating
class members' rights under the Eighth and Fourteenth Amendment
through the conditions under which the Sheriff's office confines the
class members;
c. whether the policymakers of the Sheriff's office instituted the conditions of
confinement, condoned such conditions, and/ or were deliberately
indifferent to them; and

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d. whether Defendant Neil failed in his supervisory responsibility to have
avoided the violations of class members' rights.
36. The claims of the Plaintiffs are typical of the claims of the class.
37. Plaintiffs will fairly and adequately represent the interests of the class.
Plaintiffs are represented counsel who has had experience in class actions and jail
conditions litigation.
38. The party opposing the class the class has acted or has refused to act on

grounds that apply generally to the class as a whole, so that final injunctive
relief and corresponding declaratory relief is appropriate for the entire class.
39. The questions of law and fact common to the members of the class predominate
over any individual issues that may exist.
40. A class action would be the most fair and efficient method of adjudicating the
class members claims and therefor the superior method of adjudication.

Count I —Class Claims pursuant to 42 U.S.C. S1983 for violations of the
Eighth and Fourteenth Amendments
41. Each preceding paragraph of this complaint is incorporated herein.
42. The Defendant has violated Plaintiffs' and class members' rights under the

Eighth and Fourteenth Amendments by subjecting Plaintiffs and class
members to dangerous conditions of confinement and creating a substantial
risk of serious harm to Plaintiffs and not incidentally to Deputy Sheriffs
working in the

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Hamilton County Justice Center, and, in fact, causing serious harm to
Plaintiffs and class members.
43. The policies, customs and/ or widespread practices of the policy members of the
Hamilton County Sheriff's Office are the moving force behind and the cause of
these violations.
44. As a direct result of Defendants conduct as described above, Plaintiffs have
suffered both physical pain and serious emotional stress.
45. In addition, it is likely that many of the class members have suffered both physical
as well as emotional injuries as a result of Defendant's conduct described above.

Count Il — Plaintiff Robinson's individual claim pursuant to 42 U.S.C. S1983
for a violation of the Fourteenth Amendment
47. Each preceding paragraph of this complaint is incorporated herein.
48. The confining of the Plaintiff Robinson to solitary confinement for four days for
his mere complaining of his inability to sleep on the floor in a "boat" because of
his medical condition and resulting pain is a violation of Plaintiff Robinson's
rights under the Eighth and Fourteenth Amendment to the United States

Constitution.
Requests for Relief
WHEREFORE, Plaintiffs request this Court to:
a. Certify this case as a class action pursuant to Rule 23 (b)(2) of the

Federal Rules of Civil Procedure;

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b.

Issue a preliminary and permanent injunction against the Defendant
enjoining the Defendant from using "boats" or any other temporary
sleeping fixture as a means of housing inmates beyond the cell
capacity of the Hamilton County

Justice Center;
c.

Enjoin Defendant from maintaining dangerously high inmate
population numbers;

d. Award Plaintiff Robinson damages for his pain and suffering for having

been confined in solitary confinement;
e. Award Plaintiffs' counsel reasonable attorneys fees;
f.

Grant such other relief as is just and necessary.
Respectfully submitted,

Robert B. Newman
Robert Brand Newman (0023484)
215 E. 9 th St. Ste. 650

Cincinnati, OH 45202 513-639-7000
robertnewman@newman-meeks.com

s Michael . O'Hara
Michael J. O'Hara ( 0014966 )

O'Hara, Taylor, Sloan & Cassidy
25 Town Center Blvd. Ste. 201
Covington, KY 41017 859-2212000 mohara@oharataylor.com

s Marc Mezibov 0019316
Mezibov Butler
615 Elsinore Pl. Ste. 105

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Cincinnati, OH 45202 513-621-8800

JURY DEMAND

Plaintiffs demand trial by jury as provided by law.
s Robert B. Newman

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HAMILTON COUNTY SHERIFF'S OFFICE
PagebAtl gtlßAitPdå.
"Date Reviewed:

CORRECTIONS

Date Assigned: INMATE GRIEVANCE Date Due:
Date Returned:

Inmate's ame

ID Number

Housing Location

rievance

NATURE OF GRIEVANCE:

Inmate's

ibOEIVED:

ature

IJNIT MANAGER:

COMMENTS:

DATE REFERRED:
DATE RECEIVED:

TO:
NMATE'S

DEPARTMENT
HEAD. SIGNATURE AND DATBRETURNEDtro CLASSIGICÅi10N
DEPT:
DATE RECEIVED
COMPLETED GRIEVANCE
01-31-02

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HAMILTON COUNTY SHERIFF'S OFFICE
CLASSIFICATIONS DEPARTMENT

SENT TO:

FILE
Date Reviewed:

CORRECTIONS

Date Assigned:

INMATE GRIEVANCE

Date Due:
Date Returned:

Inmate's Name

ID Number

Housing Location

Date of Grievance

NATURE OF G IEVANCE: q
e

Inmatf's Signature
RE EIVED:

DATE REFERRED:

would

+0

TO:
DEPT:

DATE RECEIVED
COMPLETED GRIEVANCE
01-31-02

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HAMILTON COUNTY SHERIFF'S OFFICE
DATE RECEIVED:

ACTION TAKEN:

INMATE'SSIGNATURE:
DEPARTMENT HEAD SIGNATURE AND DATERETURNEDTO CLASSIGICATION
CLASSIFICATIONS DEPARTMENT
SENT

DATE:
3131

Date Reviewed:

CORRECTIONS

Date Assigned:

INMATE GRIEVANCE

Date Due:
Date Rdturned:

Inmate's Name

ID Number

Housing Location

Date of Grievance

NATURE OF GRIEVANCE: ,

DEPT:
DATE RECEIVED
COMPLETED GRIEVANCE
01-31-02

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HAMILTON COUNTY SHERIFF'S OFFICE
e.

Inmate's Signature
UNIT MANAGER:

RECEIVED:
COMMENTS:

DATE REFERRED:
DATE RECEIVED:

TO:
ACTION TAIÆN:

,mMATE'SSIGNATURE:
DEPARTrvmNT HEAD SIGNATURE •AND DATERETURNED TO CLASSIGICATION

CLASSIFICATIONSDEPARTMENT
SENTTO:

FILEDATE:

DEPT:
DATE RECEIVED
COMPLETED GRIEVANCE
01-31-02

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14
HÅIVILTON COUNTY COURT OF cmn,/10N PLEAS
DIY1s10N HAMILTON
COUNTY,
STATE OF OHIO Case No. Bl 701492

Plainti"MJLT0N COUNTY

(Judge Jerome J. Metz)
vs.

AUG 25 2017

SAMUEL ROBIN9NAB PUREVAL

MOTION
MITIGATE

TO

SENTENCE

COMMON PLEAS COURTS

COPY FILED

Defendant.

Now comes the Defendant, through counsel, and respectfully request the Court the Court mitigate his
sentence. Mr. Robinson pleaded guilty to the sole count of the indictrnent, possession of cocaine (F5). qn June 13,
2017, the Court sentenced Mr.
Robinson to 180 days in the Justice Center, and 3 years ISP probation. As a condition of probati.on, the Court ordered Mr.
Robinson to enter and complete the Men's Extended Treatment Program. For the reasons set forth herein, Mr. Robinson is
respectfully requesting the Court to mitigate ffs sentence. Specifically, Mr. Robinson is respectfully requesting that the Court
permit him to enter into outpatient substance abuse treatment and avoid any further incarceration or lock-up facility.
Respectfully submitted,

Goldberg,
Schuh
2662 Madison Road

&

LLP

Cincinnati, Ohio 45208

(513)
(513)

321-2662
321-0855

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(Fax)
mschuh@sandg.net
MEMORANDUM
TN SUPPORT
Mr. Robinson is a very sick man who suffers from chronic pain, hypertension,
and avascular necrosis. Mr. Robinson is scared for his health, and does not believe
that the Men's Extended Prpgram nor the Justice Center is capable of providing the
medical care he needs. In a perfect world, Mr. Robinson would like to secure
outpatient treatment
through the Talbert'House. He believes the Talbert House would also help him obtain the medical care that he
needs.

For the Court's review, counsel has attached medical records provided by Mr.
Robinson dating back to 2013. See Exhibits A though G. The medical records are not
comprehensive, but should serve to establish Mr. Robinson's long standing health
problems.
Mr. Robinson struggles from avascular necrosis of the hip. Avascular necrosis
causes a bone to die due to a lack of blood supply. This condition causes him extreme
pain, and resulted in a total hip arthroplaÅty of the left hip in 2013. (See Ex. B, p.6, and
Ex. G). Despite the replacement of the left hip, Mr. Robinson still suffers from
avascular necrosis. The diaglosis is specifically mentioned in the medical records dated,
November 7, 2014 (Ex. F, p. 2 — discharge instructions), May 3, 2015 (Ex. E, p. 3), and APIi122, 2017
(Ex. C, p. 2), and June 19, 2017 (Ex. B, p. 5).
Mr. Robinson also suffers from chronic pain. In the medical records dated April

22, 2017), Mr. Robinson's diaglosis reads, "CHRONIC PAIN SYNDROME,

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AVASCULAR NECROSIS (HCC), CHRONIC PAIN OF BOTH SHOULDERS,
CHRONIC PAIN OF BOTH ANKLES, BILATERAL HIP PAIN, and KNEE
EFFUSION, LEFT." (Ex. C, p 2). Chronic pain is also
specifically referenced in the medical records dated May
3, 2015 (Ex. E, p.3), and November 7, 2014 (Ex. F, p. 1)
Robinson reports to counsel that he experience the most severe
pain in his shoulders. Mr. Robinson had an appointment to see an orthopedic
specialist regarding his shoulder on August 16, but missed his appointment
because he was locked up in the Justice Center.

Mr. Robinson's daily medication ih listed in his
records dated June 27, 2017 (Ex. A, p. 1). For pain, Mr.
Robinson takes amitriptyline (1 tablet nightly), asprin (1
tablet daily), oxyCODONE-aceteaminophen (1 tablet every 8
hours, as needed). Mr. Robinson also takes Lisinopril and
hydrochlorothiazide to treat high blood pressure.
Mr. Robinson does not have access to his medicines in
the Justice Center (other than: aspirin), and as a result,
has suffered immense discomfort. Further due to jail
overcrowding, Mr. Robinson vvas given the difficult choice
of sleeping on the floor, or in segegation.
For the foregoing reasons, Mr. Robinson respectfully requests that the Court
consider mitigating his sentence such that Mr. Robinson can avoid lock-up, and secure
the medical attention he desperately needs.

Respeqtfully Submitted,

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Matthew
08511 )
Attorney. for Samuel Robinson
Schuh & Goldberg, LLP 2662
Madison Road
Cincinnati, Ohio 45208

(513)
321-2662
(513)
321-0855
(Fax)
mschuh@sandg.net

CERTIFICATE OF SERVICE
I hereby certify that I have served atcopy of the foregoing Demand upon the
Office ofthe Hamilton County Prosecuting Attorney.

Attorney for Samuel Robinson

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Commissioner Todd Portune
President, Board of County Commissioners

Commissioner Portune,
This morning I received a thorough report from my Jail Commanders detailing a number of
concerns related to overcrowding at the Hamilton County Justice Center. As you know we have
had numerous meetings regarding this issue. For approximately a year now I have been warning
all county agencies of the disturbing and unsustainable upward trend of our inmate population
count at thé jail As the Commanders pointed out in their letter to me (attached) we reached a
boiling point this week. I cannot and will not jeopardize the safety of my Deputies and subject
them to an ongoing volatile, dangerous environment in our jail. Nor will I put the inmates,
medical staff and others in harm's way, I have a statutory obligation to provide for the care,
custody and control of the individuals being housed in our facility as well as keep the peace.
Under our current situation I simply cannot fulfill those obligations. Therefore, as of today I am
officially notifying you. I have declared a "State of Emergency" at the Justice Center. I have
reached out to neighboring counties to determine their ability to house a number of our inmates
in an attempt to alleviate part of our overcrowding.
I'll remind you this is not an easy decision, but it is the right thing to do and my only option.
State law does not allow me to alter inmate sentences. Your own \County Risk Management, as
well as the Hamilton County ProsecutorJs Office and State Jail Inspectors all concur we are now
well outside of acceptable practices at the jail. I have no choice but to act, and act I will, for the
safety of everyone involved. As always I look forward to continuing to work with your Board,
County Administration and other county agencies involved in criminal justice to look for both
short term and long term solutions to this pressing problem.
Respectfully,

Sheriff Jim Neil

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HAMILTON COUNTY
MERDEPARTMENTAL CORRESPONDENCE

TO:

Sheriff Jim Neil
Via Chain of Command

AT:

H.C.J.C.

SUBJECT: Overcrowding
Sheriff Neil,

FROM:

Major Chris Kptteman
Jail Services Division

DATE:

August 14, 2017

As you areE aware, we are currently overating under a i State of Emergency at the Justice l Center.
Since mid-June we have been consistently housing 25 Hamiltori County inmates at the Butler County
Jail to help ageviate our State of Emergency. Unfortupate: , moving these inmates has provided only
minimal relief of the overcrowding at the Justice Cen er, and at a steep cost. Every 30 days we are
charged a significant fee in excess of $58,000. Despite this relocatjqn, each night we are left with an
average of 65 to 75 inmates for whom there is no cell in which Ito secure them and without a bed to
sleep. These overflow inmates are currently being distributed throughout the rest of the Justice Center
to sleep on "boats" in the open dayÆpaces. Due to jail minimum standards, thése overflow inmates
must have access to a working toilet an.d because of the current design of the Justice Center, the only
available toilets are inside cells. Therefore, we must keep a cell unoccupied and open to the overflow
inmates sleeping in the open day-spaces. Through thß course of action, we are losing the ability to
house two inmates in every one of these cells.
Due to the financial burden of inmates at Butler County, we hav been tirelessly researching ways to
return these inmates to the Justice Center. In order to o so, wp had to consider ways to increase our
capacity. We havé been able to two immediate sdlutions. Both require an initial cost which would
be recouped in less than a month.

Several years ago the showers were remodeled and a decision was made to remove all toilets in the
day-space areas. Due to jåil overcrowding, we are implementing a temporary solution and have inmates
sleeping the day-spaces. As stated previously, this requires us 10 leave one open cell in each affected
unit so that the inmates have access to a toilet. We are cuirentLy utilizing 16 different units as overflow
units; as a result, we have 16 cells that we cannot utilize to house inmates. Ifthese cells were all doublegelled, 32 more Inmates could potentially be housed at the Justice Center.
It is the recommendation of the Jail Command Staff that the Boatd of County Commissioners
purchase 26 toilets to be re-installed in all of the larger units of the Justice Center. By doing this, we
would have much greater me*ibility to ladjust the floater units when needed' Due to the current State
of Emergency, We are proposing that .16 toilets be purchased and installed immediately for each
one of our floater units currently housing overfloW inmates: The approximate cost for the purchase
of the 16 of the 26 toilets would be approximately $48,000.
The Justice Center curYently has 136 single bed cells. We researched the cost of purchasing
additional Beds and initially priced them at approximately $250 per bed. While we were in the
process of pricing new beds, a Sergeant •suggested that we contact the owners of Queensgate

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Correctional, tsince he was aware that they have used beds stored in that facility. After some
negotiations, they agreed to sell us the beds at an extremely discounted rate i of $25 per bed, totaling
a mere: $3,400. Therefore, we are requesting that the Boqrd of County Commissioners

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purchase an additional 136 beds and install them in the single-bed cells, making them dopblecelled
cells; this would potentially allow us to house an additional 136 inmåtes depending on classification.
Although the installation of the toilets and beds will 'not alleviate the overcrowding, it would be a .
large step in working towards our goal of not being forced to house inmates iat Butler County. Again,
the approximate cost of housing 25 inmates! a! Butler County is $58,000 a month. In comparison;
the cost of installing the additional t6ilets and beds is approximately $5 1 ,400. By installing the
additional beds and toilets, the' likelihood of sendiilg additional inmates to Butler County would be
dramatically cut. Firthermore, tbe possihility of being able to return the inmates currently housed in
Butler County would increase.
Although neitber of these suggeétions will completely eliminate our overcrowding, it will increase
our in the manner . in which we Can house inmates. Iti is, therefore, our recommendation that
discussions be held with the Commissioners to determine if they would
purchase the additional beds and toilets.

Respectfully submitted,

Commander Dave Turner
Jail Services Division

Major Chris Ketteman!
Jail Services Division

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