Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974), was a landmark case decided by a United States federal court called the Fifth Circuit Court of Appeals. The case had to do with the rights of prisoners at Mississippi State Penitentiary (usually called "Parchman").

A usual prison camp at Parchman

Gates v. Collier is a very important case for prisoners' rights. It was the first case to rule that many types of physical punishment against prisoners are cruel and unusual punishment, and are against the Eighth Amendment to the United States Constitution. It was also the first time that the Supreme Court started supervising how the country's prisons were being run.



The Eighth Amendment to the Constitution says that the state cannot give cruel and unusual punishments to anyone.

Parchman opened in 1903. At the prison, there was a program called the "trusty system." This was a system where some prisoners had more rights and freedoms than others. They also had power over the other inmates.[1]

The Governor of Mississippi, James K. Vardaman, said the prison was run “like an efficient slave plantation.”[1] Trusties had guns and were allowed to shoot at prisoners who stepped out of line. Other punishments were painful and severe. The prison also segregated (separated) black and white prisoners.[2]

For years, there were protests over civil rights abuses at Parchman. Eventually, civil rights lawyer Roy Haber began to collect evidence of the abuse.[3] With Haber as their lawyer, four prisoners filed a lawsuit in federal court, saying that conditions at the prison were cruel and unusual. They said that prison trusties and guards punished and tortured prisoners in ways that were painful and humiliating on purpose.[2]

Lower court decision


The prisoners' lawsuit, Gates v. Collier, 349 F. Supp. 881 (1972), went first to a federal court called the United States District Court N.D. Mississippi, Greenville Division. This court ruled strongly in favor of the prisoners The court found that Parchman's trusties and guards gave many cruel and unusual punishments, including:[2]

  • Beatings
  • Shooting at or around prisoners, sometimes hitting them
  • Taking away prisoners' clothes
  • Turning fans on prisoners while they were naked and wet
  • Not giving inmates food, mattresses, or items for hygiene
  • Handcuffing prisoners to fences or bars
  • Using a cattle prod on prisoners
  • Forcing prisoners to stand for long periods of time
  • Putting inmates in stress positions (positions that are painful)

The court ruled that the prison had violated the prisoner's rights under the First, Sixth, Eighth, and Fourteenth Amendments to the Constitution.[2] The court ordered the prison to make many different changes to fix these abuses. It also ordered the prison to end the trusty system.[2]

Fifth Circuit decision


The state of Mississippi appealed this decision to the Fifth Circuit Court of Appeals. However, the Fifth Circuit also agreed with the lower court's earlier decision.[4] Federal Judge William C. Keady wrote that Parchman Farm had violated "modern standards of decency". He ordered an immediate end to all unconstitutional conditions and practices.[5]

The Fifth Circuit Court ruled that Parchman was using cruel and unusual punishments on its prisoners. It was violating their rights to be protected by the laws – which apply to prisoners, too.



After the court decision, Parchman had to end its trusty system. It also stopped segregating its prisoners.[5]

After the court decision, other states that used the trusty system had to stop using it too. These states included Arkansas, Alabama, Louisiana, and Texas.[5]

This decision also set some important precedents. One is that even prisoners have the right to be protected from cruel and unusual punishment. Americans' constitutional rights do not all stop when a person goes to prison. It also limited the type of punishments that prisons can use.[1]



  1. 1.0 1.1 1.2 Winter, Margaret; & Hanlon, Stephen F. (2008). Parchman Farm Blues: Pushing for Prison Reforms at Mississippi State Penitentiary. Litigation 35 1: 1-8.
  2. 2.0 2.1 2.2 2.3 2.4 Gates v. Collier, 349 F. Supp. 881 (1972) (N.D. Miss. 1972).
  3. Robben, Janine (2007). "Lessons from Parchman Farm". Oregon State Bar Bulletin. Oregon State Bar. Retrieved March 29, 2016.
  4. Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974).
  5. 5.0 5.1 5.2 Gioia, Ted (2006). Work Songs. Oxford University Press. p. 201. ISBN 978-0822337263.