In 1972, prisoners Michael V Costello and Robert K Celestino filed separate pro se complaints in the United States District Court for the Middle District of Florida alleging overcrowded conditions and inadequate health care in Florida prisons. These claims were consolidated, amended by court-appointed counsel, and authorized by Senior United States District Judge Charles Ray Scott as a class action for declaratory and injunctive relief on behalf of all present and future Florida Department of Corrections (DOC) inmates. In their amended complaint, the plaintiffs alleged that the overcrowding and inadequate medical care in Florida prisons constituted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The plaintiffs sought a preliminary injunction ordering defendant Louie L. Wainwright, as Director of the Florida Division of Corrections, to reduce Florida's inmate population to "normal capacity" within the following year and to close Florida's prisons to new inmates. Judge Scott initially denied the injunction without prejudice, finding it was "moot" because defendant Wainwright had himself" closed the prison system to additional inmates because of the danger to the health and lives of the inmates."
Shitama, Mariko K.
"A Pioneer in Prison Reform: Costello v. Wainright and its Paradoxical Legacy in Florida Prisons,"
Florida Historical Quarterly: Vol. 92:
2, Article 21.
Available at: https://stars.library.ucf.edu/fhq/vol92/iss2/21