Amber Baylor Visiting Assistant Professor of Law, Widener University Delaware School of Law ...

35 Pages·2017·0.92 MB·English

by  Amber Baylor

Amber Baylor
Visiting Assistant Professor of Law, Widener University Delaware School of Law
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NARRATIVE OF A LITIGIOUS FREED WOMAN
OR
NARRATIVE OF A LITIGIOUS WOMAN: SURFACING LIBERTY INTERESTS IN DETENTION
The women in Carol “Crooksie” Crooks’ unit at Bedford Hills Correctional Facility
watched warily as the guards approached Crooks on August 28, 1974. A correctional
officer was in the midst of an intense argument with Crooks, who, yelling that she
needed to go to the infirmary, seemed oblivious to the danger of antagonizing the
officer.1 As their voices rose, nearby officers ran towards the guard and the
prisoner. They surrounded Crooks, quickly leveling her down to the floor out of the
unit. 2 Crooks was hogtied, with her legs and hands cuffed to a long rod, and
dropped in a wagon headed towards a building that housed the solitary confinement
cells. 3 The women that witnessed the takedown feared for Crooks’ safety. Crooks
had endured solitary many times before. 4 Yet this time, the takedown took place
after Crooks’ success in an ongoing lawsuit against the prison. A preliminary
injunction from the court directed the prison not to hold Crooks in solitary
confinement. Crooks’ fate would indicate whether or not the women could hope to
rely upon the prison’s compliance with court-ordered protection.

On that August night in 1974, a collective of women in the upstate New York prison
gathered together.5 They had an urgent choice to make. Allow Carol Crooks to be
dragged by their jailers, yet again, to the solitary box – in violation of a federal
district court order protecting her, or rebel.

Our law accepts that people in prison will experience diminished liberties.6
Procedural protections within prison disciplinary hearings are a critical way to

1Women Against Prison, Dykes Behind Bars, No. 1 DYKE, A QUARTERLY (1975).

2 Women Against Prison, Dykes Behind Bars, No. 1 DYKE, A QUARTERLY (1975).

3 Carol Crooks, Interview, (2015) (on file with author).

4 Women Against Prison, Dykes Behind Bars, No. 1 DYKE, A QUARTERLY (1975).

5 Women Against Prison, Dykes Behind Bars, No. 1 DYKE, A QUARTERLY (1975).

6Wolff v. McDonnell, 94 U.S. 2963 (1974); James Robertson, IMPARTIALITY AND PRISON
DISCIPLINARY TRIBUNALS, 17 NEW ENG. J. ON CRIM. & CIV. CONFINEMENT 301 (1991); Cindy Chen,
THE PRISON LITIGATION REFORM ACT OF 1995: DOING AWAY WITH MORE THAN JUST
CRUNCHY PEANUT BUTTER, 78 ST. JOHN’S L. REV. 203 (2004).
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Visiting Assistant Professor of Law, Widener University Delaware School of Law
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safeguards those precious remaining liberties.7 Recapturing the historical
experiences of lives affected by women’s prisons is necessary for critical
investigations of discipline in prison.8 Carol Crooks and her colleagues at Bedford
Hills spearheaded a number of formal complaints about discipline proceedings and
privacy concerns at Bedford Hills prison. They were amongst the earliest litigants of
post-Attica, conditions-based, prisoners’ rights claims. 9This article emanates out of
work capturing the oral history accounts of people that staged a rebellion at Bedford
Hills prison and challenged the prison’s disciplinary proceedings. The work of the
women that rebelled at Bedford Hills 40 years ago affected protections for people in
prisons across the state, benefitting all of the state’s prisoners, not solely those in
women’s facilities. Their struggles for dignity, too, are not limited in application to
women’s prisons, but rather can be understood as common to all harmed by
conditions of confinement concerns in prisons.

The accounts collected and referred to in this article document women’s
experiences in the criminal legal system. Investigations into women’s historic
experiences have not been integrated into the dominant narratives of the prisoners’
rights movement. Instead, accounts of incarceration in women’s prisons have been
repressed or catalogued as niche, rather than exemplar.10 Historic narratives of
women in prison justify centering the experiences of those in women’s prisons.
Women’s struggles have been integral to the struggles for dignity in incarceration.
As feminist criminologist Ngaire Naffine wrote in 1987, "Feminist theory is likely to
dismantle the longstanding dichotomy of the devilish and daring criminal man and
the unappealing and inert conforming woman. The threat it poses to a masculine
criminology is therefore considerable.”

7 Wolff v. McDonnell, 94 U.S. 2963 (1974); Donald Tibbs, Peeking Behind the Iron Curtain: How Law
“Works” Behind Prison Walls, 16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.
8 See Mario Barnes, Black Women’s Stories and the Criminal Law, 39 U.C. Davis L. Rev. 941 (2006);
Robert M. Cover, NOMOS AND NARRATIVE, 97 HARV. L. REV. 4 (1983); Colleen Sheppard, Sarah
Westphal, NARRATIVES, LAW AND THE RELATIONAL CONTEXT: EXPLORING STORIES OF
VIOLENCE IN YOUNG WOMEN’S LIVES, 15 WIS. WOMEN’S L.J. 335 (2000); Daniel A. Farbera Suzanna
Sherry, TELLING STORIES OUT OF SCHOOL: AN ESSAY ON LEGAL NARRATIVES, 45 STAN. L. REV.
807 (1993); Robin L. West, THE DIFFERENCE IN WOMEN’S HEDONIC LIVES: A
PHENOMENOLOGICAL CRITIQUE OF FEMINIST LEGAL THEORY, 15 WIS. WOMEN’S L.J. 149 (2000).
9 I first encountered the story of Carol Crooks, Bedford Hills and the Matteawan Six in Victoria Law’s eye-
opening book on women’s uprisings in U.S. prisons, Resistance Behind Bars. Sociologist Juanita Cotto-
Diaz describes Bedford Hills and disciplinary hearings at the time of the uprising in meticulous detail in
GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS (1996).

10 KIMBERLÉ W. CRENSHAW AND ANREA RITCHIE, SAY HER NAME: RESISTING POLICE BRUTALITY
AGAINST BLACK WOMEN (2015),
http://static1.squarespace.com/static/53f20d90e4b0b80451158d8c/t/560c068ee4b0af26f72741df/14436286
86535/AAPF_SMN_Brief_Full_singles-min.pdf
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Visiting Assistant Professor of Law, Widener University Delaware School of Law
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Once we recognize the work of organizers within this women’s prison as
forerunners of modern prisoners’ rights litigation, then it is not too great a leap to,
as modern movements for women in the criminal legal system advocate, apply a
women-centered lens to critiques of the criminal justice.11 The story of Bedford
Hills indicates that the experience of women within the system was central, and
possibly de-centered, because of the danger they represented to the status quo.
Their accounts document both the horrors of incarceration and the strategic efforts
to challenge solitary confinement. The impact of the work of women like those at
Bedford Hills created a path for prisoners throughout the state to challenge the
treatment they received behind prison walls, deprived from protection of public
scrutiny. 12 Capturing and centering the stories that have been marginalized to
gender-specific niches, we learn how inclusion of these accounts might have
informed our current understanding of the criminal legal system. 13

In Part I of this paper, I focus on the story of the Bedford Hills Prison uprising, as
gathered in oral history interviews with a leader in the prison, Carol Crooks, Steven
Latimer, an attorney for the women, and Janis Warne, the warden of the facility. In
Part II, I argue that capturing this history is necessary for advocates working to
advocate for procedural protections for people in prison. As an example, I mine the
historical accounts of the rebellion at Bedford Hills Correctional Facility in 1974 for
its insights into a discussion at the forefront of the national dialogue surrounding
incarceration: use of solitary confinement. In Part III, I examine what these
accounts might contribute to the work of advocates both working to expose

11 One example of centering women’s experiences in criminal justice is the organizing around “Say Her
Name.” See KIMBERLÉ W. CRENSHAW AND ANREA RITCHIE, SAY HER NAME: RESISTING POLICE
BRUTALITY AGAINST BLACK WOMEN (2015),
http://static1.squarespace.com/static/53f20d90e4b0b80451158d8c/t/560c068ee4b0af26f72741df/14436286
86535/AAPF_SMN_Brief_Full_singles-min.pdf.; Andrea Ritchie, #SayHerName: Racial Profiling and
Police Violence Against Black Women (Interview), NYU Law & Social Change (August 10, 2016),
https://socialchangenyu.com/sayhername-racial-profiling-and-police-violence-against-black-women/.
Centering necessarily repudiates gender-essential zing responses to grappling with the concerns of women
in prison. Women who are not within the gender normative mold, i.e. not mothers, non-gender normative in
presentation, those convicted of violent offenses – may not benefit from gender-essentializing reforms.
This is especially problematic since women that do not fall within gender norm expectations are more
vulnerable to punitive sentencing, including prison time, in the first place. To the extent that women who
are in prison have been affected by structural sexism within the state in negotiating their lives, fixed ideas
about womanhood, and women worthy of assistance, only further disserves those in women’s prisons.
Unlike responses that position the problem being encountered as the unique unsuitability of incarceration
models for women, centering women’s experiences uses these accounts to challenge the premise of a
justice system that relies upon incarceration to improve society.
12 Powell v. Ward, 542 F.2d 101 (1976).
13 Mario Barnes, Black Women’s Stories and the Criminal Law, 39 U.C. Davis L. Rev. 941 (2006).
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Visiting Assistant Professor of Law, Widener University Delaware School of Law
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injustice for those in women’s prisons, but also critique use of solitary confinement
overall.

I. Resistance at Bedford Hills

A. The Adjustment Committee
Prior to 1974, the women of Bedford Hills Correctional did not expect much to
happen in their favor during disciplinary, or what the state called “Adjustment
Committee,” hearings.14 In reality, the women experienced a show of process
without much substance. When a woman in a New York State correctional
institution was accused of a violation of the prisons regulations, she would be
brought to the Committee that would decide whether the infraction had occurred
and the proper sanction for the infraction.15 The Adjustment Committees at Bedford
Hills were comprised of administrative officials from the prison itself. 16 They would
hear from witnesses, often their own colleagues or people in prison under their
watch. A representative from the prison advocated for a particular sanction.17 The
representative, likewise, is often a colleague of the members of the board. 18 There
was often little or no distinction in the hearings between the board and the prison’s
representative advocating for punishment. The warden might have ex-parte
conversations with members of the Committee, including discussions about what
might be the proper sanction for the person before the Committee.19 The Committee

14 Carol Crooks, Interview, (2015) (on file with author); JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND
THE STATE LATINA AND LATINO PRISON POLITICS (1996).
15 JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS
(1996); see also Donald Tibbs, Peeking Behind the Iron Curtain: How Law “Works” Behind Prison Walls,
16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.
16 JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS
(1996); see also Donald Tibbs, Peeking Behind the Iron Curtain: How Law “Works” Behind Prison Walls,
16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.

17 JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS
(1996); see also Donald Tibbs, Peeking Behind the Iron Curtain: How Law “Works” Behind Prison Walls,
16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.

18 JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS
(1996); see also Donald Tibbs, Peeking Behind the Iron Curtain: How Law “Works” Behind Prison Walls,
16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.
19 Powell v. Ward, 542 F.2d 101 (1976); Powell v. Ward, 392 F.Supp 628 (1975); Crooks v. Warne, 516
F.2d 837 (1975).
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did not provide people with notice of their right to call witnesses on their behalf, so
often it was solely the word of the person charged against that of a staff member or
other witnesses, including other people incarcerated at the prison, called into the
hearing by the staff member. 20

The women before the Committee were unrepresented and often had no idea what
their exact charges were, since they received no notice of the charges.21 Thus a
woman could be sanctioned for some prison violation and even after the sanction,
have no idea what regulation was allegedly violated. The Committee was made up of
staff from the facility. For most part, women charged with an infraction expected to
be at the mercy of the Committee.

Punishment levied out by the Committee included extended stints time in the barren
solitary barracks in a distant part of the prison.2223 Time in solitary confinement
often began before the hearing was conducted.24 So often it was the case that
women who had already been placed in solitary confinement as a part of the
disciplinary measure waited there for weeks before getting to the hearing, where
they were formally sanctioned to segregation, and left without any documentation
provided to them about the process they just undergone. 25

The journey of the women known as the Matteawan Six at Bedford Hills magnified
the discussion of liberty interests of those who are already incarcerated. The
Matteawan Six and the women of Bedford Hills’ uprising pursued a number of civil
actions against the prison annunciating the importance of their liberty interest. The
personal accounts – of the lives of the women involved, the risks they face, the
deprivations they experienced, and the organizing they did to protect their dignity
while in prison is a necessary part of understanding the interest at stake. By 1976,
the women changed procedural protections for disciplinary hearings. Yet that part

20 Powell v. Ward, 542 F.2d 101 (1976); Powell v. Ward, 392 F.Supp 628 (1975); Crooks v. Warne, 516
F.2d 837 (1975); JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON
POLITICS (1996); see also Donald Tibbs, Peeking Behind the Iron Curtain: How Law “Works” Behind
Prison Walls, 16 SOUTHERN CALIFORNIA INTERDISCIPLINARY LAW JOURNAL 137.

21 Powell v. Ward, 542 F.2d 101 (1976);
22 Crooks describes the solitary cells at the facility:
“Like you would go into a bathhouse, go into a pool house, those cement blocks. That’s
what it was made of, cement blocks and a linoleum floor. And you have a basement
hooked on the wall and a barefaced toilet – no toilet seat. It was a four by eight room.”
Carole Crooks, Interview, (2015) (on file with author).
23 Stephen Latimer, Interview, (2016) (on file with author).
24 Powell v. Ward, 542 F.2d 101 (1976).
25 Powell v. Ward, 542 F.2d 101 (1976).
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of the story is not something that can be gleaned from the record, or even outside
reporting of events. The nuances of those interests and the tactics of the women in
challenging procedural deficiencies are only revealed through the intimate accounts
of their experiences.

The women were at the forefront of the prisoners’ rights movement in post Attica
America.26 By the end of their first series of lawsuits, New York State was mandated
to provide notice of the charges the woman is facing in a disciplinary hearing, a
record of what ultimately happened decided in the hearing and the bases for the
decision, the ability to call witnesses on her behalf (where witnesses were not
deemed a danger to security), and the right to a hearing within seven days of
segregation.27 The impact of their work reverberated not only through prisons in
New York State, but those around the country.28

B. From Hustler to Resistor, Carol Crooks Builds a Dignity-based Philosophy
The work was sparked by a woman called “Crooksie.” Carol Crooks was born in
Brooklyn, New York to family that had migrated from the South.29 As a young person
raised in a home with a lot of people and no money, Crooks figured out ways to earn
the things she wanted or needed outside of her home.30

Until the 1970s, Carole Crooks considered herself to be, as she describes it, a
“hustler.”31 She wore the tag like a coat of steel, not altogether proud, but, at the
time, not ashamed. A “hustler,” according to Crooks, was someone that lived off of
work in the city’s underground economies. “Hustler” was a term Crooks used to
describe a resourceful, irreverent survivor. Yet the compulsion to “hustle,” implies a
social order that had structurally relegated Crooks and her peers, by virtue of race,
class and gender, to a life on margins. Crooks began hustling as a teenager in

26 JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO PRISON POLITICS
(1996).
27 Powell v. Ward, 542 F.2d 101 (1976).
28 Cite cases; Tessa Melvin, Fund for Inmates Celebrated, June 26, 1983.
29 Carol Crooks, Interview, (2015) (on file with author).
30 Carol Crooks, Interview, (2015) (on file with author).

31 Carol Crooks, Interview, (2015) (on file with author).
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Brooklyn. As a young woman she spent Dickensian stints at the New York Training
School for Girls, a reformatory in upstate New York.3233

Little to no research has been done on the connections between the experiences of
children at correctional institutions for girls and organizing within women’s prisons.
Stories of incarceration at these institutions demonstrates how deeply the various
arms of the criminal legal system have affected women and provides a basis for
understanding why effective organizing became a key contribution of women
prison. Crooks, like many women and her colleagues, was first trained in the work of
organizing while incarcerated by her time in juvenile reformatories. As a child and
teen, Crooks was incarcerated at Hudson Training Institute for Girls. Schools like
the Training Institute were created for “incorrigible girls.”34

At the Training School for Girls, she learned how to access many of these networks.
As she recalled:

I started doing stuff I learned up in these reformatory schools. Selling
drugs. They talk about selling their bodies, they talk about selling
drugs, they talk about con artists. They talk about a whole lot of stuff
you wouldn’t think kids would talk about. Because there was always
one kid that was more of a rogue than you.35

The children were also exposed early to the idea that they could not rely on the
Institute for their individual needs. The institutions were meant to instill
compliance.36 In the school the children had classes, but they also spent much of
their time engaged in wearing, menial tasks. Crooks recalls:

We used to march. We marched in the wintertime. We marched in
the summertime. That’s all we did was march. And it wasn’t clean.
Early in the morning and we’d buff the wooden floors. We’d put the
wax down and buff with our knees. My knees are dark because our

32 The New York Training School for Girls was founded in 1904 as a reformatory for “incorrigible” girls.
Prison Public Memory Project, “New York State Training School for Girls,”
https://www.prisonpublicmemory.org/blog/2014/new-york-state-training-school-for-girls.

33 Carol Crooks, Interview, (2015) (on file with author).

34 Prison Public Memory Project, “New York State Training School for Girls,”
https://www.prisonpublicmemory.org/blog/2014/new-york-state-training-school-for-girls.

35 Carol Crooks, Interview, (2015) (on file with author).
36 Prison Public Memory Project, “New York State Training School for Girls,”
https://www.prisonpublicmemory.org/blog/2014/new-york-state-training-school-for-girls.

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Visiting Assistant Professor of Law, Widener University Delaware School of Law
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skin used to tear up. We used to buff with an army type of blanket
folded and go up and down these long corridors. And there would be
thirty bedrooms, thirty bedrooms, and we had to go down these long
wooded corridors, to shine up these floors. On our hands and knees.37

The children that were unable to comply were subjected to the Hudson’s Schools
version of solitary, the barracks at Cottage A.38

For people that were in institutions for girls, this incongruity is more striking than
perhaps that in institutions for men and boys. Whereas men institutions were
somewhat more obviously tailored towards control and punishment, institutions for
girls, the mission of control was hidden neatly in principles involving protection of
girls, serving as “home away from home,” and preparation to be a socially acceptable
type of woman.39

During the 1960s, demographics in the Training Institute began to shift –
increasingly the population of African-American girls began to grow.40 The era also
brought along curious sociologists, interested in applying new metrics to
understanding the lives of the girls living at the Training Institute. 41 Their studies,
though at times problematically fetishistic, demonstrate that the girls, coordinated
complex systems built on cooperation, to provide for their needs – from contraband
to familial, emotional support. According to the sociologists, the youths they
interviewed at the Training Institute called the system “The Racket.”42 Sociology
studies of women in New York City jails at that time also report that woman
attended the Training Institute mostly learned from other girls there how to make it
on the street by engaging in “The Racket.” 4344

37 Carol Crooks, Interview, (2015) (on file with author).

38 CITE Conversation with Tracy Huling.

39 CITE; Prison Public Memory Project, “New York State Training School for Girls,”
https://www.prisonpublicmemory.org/blog/2014/new-york-state-training-school-for-girls.
40 CITE Prison Public Memory Project, “New York State Training School for Girls,”
https://www.prisonpublicmemory.org/blog/2014/new-york-state-training-school-for-girls.

41 CITE

42 CITE
43 SARAH HARRIS, HELLHOLE: THE SHOCKING STORY OF THE INMATES AND LIFE IN THE NEW YORK HOUSE
OF DETENTION FOR WOMEN (1967).
44 Crooks remember how ill prepared the institution left her to function in society. Its imprint was
helplessness.

When you returned home you didn’t have anything. You didn’t have money. You [did
not know how to] answer the phone. That was the first time I witnessed my faculties of
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Crooks continued to spend time in and out of correctional facilities as a young
woman. 45 During one stint at the New York Women’s House of Detention in New
York City, while awaiting trial, she began to see an influx of women in the facility
that was not, to her mind, “hustlers.”46 She recognized this new group of women by
their formal education and reputation; many had some amount of notoriety, and
were celebrated by people outside of the facility for their “crimes.”47 The women
held a special status as “political prisoners,” and were members of activist groups
like the Black Panther Party. 48 Crooks and other women incarcerated at the facility
expected that the “political prisoners” would self-segregate from the regulars.49
Instead, these women mixed in with the others, organizing classes at the facilities, at
times teaching basic literacy, on other occasions selecting lessons from the
sophisticated Black Panther Party’s community education curriculum.50 One of
these dedicated teachers, Afeni Shakur became close to Crooks. 515253 The political

not dealing with everything in society. The noise, the cars, the streets, everything…you
waited for a matron to do that – not you.

Carol Crooks, Interview, (2015) (on file with author).

45 Carol Crooks, Interview, (2015) (on file with author).
46 Carol Crooks, Interview, (2015) (on file with author).

47 Carol Crooks, Interview, (2015) (on file with author).

48 See SARAH HARRIS, HELLHOLE: THE SHOCKING STORY OF THE INMATES AND LIFE IN THE NEW YORK
HOUSE OF DETENTION FOR WOMEN (1967).
49 Carol Crooks, Interview, (2015) (on file with author).
50 Carol Crooks, Interview, (2015) (on file with author); JASMINE GUY, AFENI SHAKUR: EVOLUTION OF A
REVOLUTIONARY (2004).
51 Carol Crooks, Interview, (2015) (on file with author). The women, Afeni Shakur and Joan Bird, were
charged alongside __ comrades with conspiracy to. The group was acquitted after trial -- the charges were
later widely acknowledged as a COINTELPRO operation. JASMINE GUY, AFENI SHAKUR: EVOLUTION OF A
REVOLUTIONARY (2004).
52 Shakur, and her only other women codefendant, Joan Bird were arrested in 1969. With bail set at
$100,000, they made an appeal for funds within the community of women philanthropists sympathetic to
their cause. The community of women raised enough money to free Shakur and Bird on bail, and they
continued to attend court appearance while on bond. In 1971, three of the women’s male co-defendants
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awareness that activists like Shakur shared with women within the system would
help spur women throughout the state in challenging their treatment inside prison.

In addition to training women received from political prisoner during the 1970s
they increasingly were able to interact with women's rights attorneys and law
students that held courses at the prison.54 Some women that were active in the
feminist movement believed that their mandate to assist women included
considering the impact of incarceration on poor women and women of color.55 One
project taken on by the feminist lawyers visiting prisons was to train women in
prison in legal research.56 Crooks recalled the advice that she received from a
woman also incarcerated at the facility, a legal research legacy of training programs.

and Party leaders fled the country, jumping bail, without alerting Shakur or Bird. As soon as the men’s
absence was apparent to the court, Bird and Shakur’s bail was revoked, despite Shakur’s pregnancy. It was
during these years, after the male party members’ betrayal of Shakur, that Crooks met Shakur. JASMINE
GUY, AFENI SHAKUR: EVOLUTION OF A REVOLUTIONARY (2004).
53 DONALD TIBBS, FROM BLACK POWER TO PRISON POWER: THE MAKING OF JONES V. NORTH
CAROLINA PRISONERS’ LABOR UNION, INC. (2010). Crooks and Shakur connected as individuals, the
dynamics of Shakur’s role in educating women in New York jails very much reflects the work of Blank
Panther Party (BPP) members in jails during this time. Much of the material for the course was rooted in
communist philosophy, international in scope, and offered critiques of capitalism, and institutionalized
racism.
While many of the readings informed the Political Prisoner Movement (PPM), it also influenced and drove
action within the Prisoner’s Rights Movement (PRM). Legal historian Donald Tibbs writes, “the Prisoners’
Rights Movement focused on legIslative reform for changing prison. PPM political prisoner movement
radicals looked beyond administrative reforms, to situate prisoners’ rights within a national, even global
struggle to revolutionize democracy.” DONALD TIBBS, FROM BLACK POWER TO PRISON POWER:
THE MAKING OF JONES V. NORTH CAROLINA PRISONERS’ LABOR UNION, INC. (2010). Despite this
distinction, the two intersected and perhaps were experienced in a unified way.
54 Ellen Barry, Women Prisoners on the Cutting Edge: Development of the Activist Women’s Prisoners’
Rights Movement, (2000); KARLENE FAITH, UNRULY WOMEN: THE POLITICS OF CONFINEMENT AND
RESISTANCE (2011); JUANITA COTTO-DIAZ, GENDER, ETHNICITY, AND THE STATE LATINA AND LATINO
PRISON POLITICS (1996).
55 Ellen Barry, Women Prisoners on the Cutting Edge: Development of the Activist Women’s Prisoners’
Rights Movement, (2000); KARLENE FAITH, UNRULY WOMEN: THE POLITICS OF CONFINEMENT AND
RESISTANCE (2011).
56 8 Women N.Y.U. Law Students and 2 Professors Teach Course to Bedford Hills Prisoners, NEW YORK
TIMES, October 14, 1973; Ellen Barry, Women Prisoners on the Cutting Edge: Development of the Activist
Women’s Prisoners’ Rights Movement, (2000); KARLENE FAITH, UNRULY WOMEN: THE POLITICS OF
CONFINEMENT AND RESISTANCE (2011).
10