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Litigation challenging the conditions in the Arkansas prison system began in 1969. In evaluating the diet and sleeping arrangements of the inmates, the physical condition of cells, and the behavior of prison guards (some of whom were inmates who had been issued guns), a District Court called the conditions which inmates were forced to face "a dark and evil world completely alien to the free world." This case involved a challenge to the practice of "punitive isolation" in Arkansas prisons which was often done for indiscriminate periods of time in crowded windowless cells.

Did punitive isolation for more than thirty days in the Arkansas prison system constitute cruel and unusual punishment as prohibited by the Eighth and Fourteenth Amendments?

The Court held that punitive isolation for longer than thirty days in Arkansas prisons constituted cruel and unusual punishment and violated the Constitution. Justice Stevens conceded that isolation in and of itself was not necessarily unconstitutional and may in fact serve an important, legitimate interest in administering a prison. However, when taken as a whole, continued Stevens, the conditions in Arkansas's prisons, combined with the severe risks to an inmate's health and safety which accompanied confinement in isolation, did constitute cruel and unusual punishment. "A filthy, overcrowded cell and a diet of 'gruel' might be tolerated for a few days and be intolerably cruel for weeks or months," Stevens concluded.