1. TO: Nathaniel Shipp, Esq.
FROM: Seth Osmun, Paralegal
DATE: May 4th, 2015
CASE NO:349 F. Supp. 881 (1972)
RE: Gates v. Collier
You have asked me to prepare a memorandum of law on the Supreme Court’s holding in
Gates v. Collier (349 F. Supp.881 (1972). The following is a brief analysis of the legal questions
and facts presented in this case.
QUESTIONS PRESENTED:
Did the alleged actions of prison officials at Mississippi State Penitentiary rise to the
level of constitutional violations?
SHORT ANSWER:
Yes. Federal investigators, upon visiting the facilities, found clear evidence that
corroborated the allegations made by Gates and fellow plaintiffs. On August 23rd, the United
States, having investigated thoroughly the conditions at MSP, joined the lawsuit as a plaintiff
pursuant to 42 USC 2000h-2, agreeing with the existence of the constitutional claims laid out by
Gates. The government’s complaint alleged that,
“the defendants have, contrary to the Fourteenth Amendment, maintained a system of
prison facilities segregated by race; and, additionally, the defendants have failed to
provide the inmates with adequate housing, medical care, and protection from assault
from other prisoners, that the conditions of the sewerage disposal and water systems
create an immediate health hazard, and that prison officials have permitted the

2. custodial staff, including inadequately trained armed trusties, to inflict cruel and unusual
punishment upon inmates in violation of the Eighth Amendment.”
FACTS:
On February 8th, 1971 Nazareth Gates, an African-American inmate confined at
Mississippi State Penitentiary, located at Parchman, MS, along with multiple unnamed inmates,
filed a class action suit against the superintendent of the penitentiary, who at the time was
Thomas Cook. Cook left the position just after the suit was filed, and his replacement, John
Collier, was then substituted as the defendant.
Gates brought suit in the United States District Court of Mississippi’s Northern District
alleging that “defendants, by their method of prison administration, have deprived the inmates
of rights, privileges and immunities secured to them by the First, Eighth, Thirteenth and
Fourteenth Amendments.” Gates also alleged that “negro inmates have been segregated and
discriminated against on the basis of race in violation of the Equal Protection Clause of The
Fourteenth Amendment.” Gates sought injunctive relief to remedy the defendant’s misconduct
and a declaratory judgement that the practices and conditions existent at the penitentiary were
unconstitutional.

3. DISCUSSION:
The 8th Amendment to the United State Constitution bans cruel and unusual
punishment. The 14th Amendment guarantees due process and equal protection under the law.
The Court determined that the conditions at MSP clearly violated both Federal and Mississippi
state law by maintaining conditions that were unconstitutional and did not meet the letter of
either Federal or State laws. The Court determined that “Parchman, in certain material
respects, has been, and continues to be, maintained in a manner violative of rights secured to
inmates by the United States Constitution, and also contrary to Mississippi law.” The Governor
of Mississippi, John Bell Williams, conceded as much during the trial, saying “"We are, in effect,
Your Honor, admitting that the constitutional provisions have been violated."
The fact that the violations were so clearly documented by investigators who visited the
penitentiary, even in the face of repeated denials by officials, and that even the Governor of
Mississippi did not contest that conditions there were unlawful, almost certainly determined
that the outcome would be favorable to Gates. The Court, in condemning unequivocally the
conditions at Parchman and in ordering immediate and sweeping changes to be made to the
way the State of Mississippi ran their prison system, sought to establish a precedent that
prisoners were still entitled to basic standards of health and safety, and that they retained due
process rights under the U.S. Constitution.
CONCLUSION:
The ruling of the Supreme Court in Gates v. Collier is now over 40 years old, and has
never been reversed. The case is frequently referenced in civil rights actions brought by prison

4. inmates, and it is acknowledged that the Courts holding also ended similar conditions in prison
systems across the south, including Texas and Louisiana, creating a ripple effect that
reverberated across the criminal justice system. This decision seems unlikely to be reversed
either fully or partially by subsequent Supreme Court rulings, as the allegations were
sufficiently serious to warrant the Court’s finding for Nazareth Gates, were confirmed by
independent investigation to be true, and the reforms ordered by the Court were put into
effect by the Mississippi State Penitentiary as required.