Hastings Race and Poverty Law Journal


Azadeh Zohrabi


The California Department of Corrections and Rehabilitation ("CDCR") considers prison gangs to be serious threats to prison safety and security and has developed a "gang validation" system to identify suspected prison gang members and their associates. The CDCR administratively segregates these prisoners from the general population by use of harsh, highly restrictive secure housing units ("SHUs"). The CDCR's gang validation process is currently applied to the Black Guerrilla Family ("BGF"), the only Black prison gang recognized by the CDCR.

This note will engage in a historical examination of the political movement that gave rise to the BGF and the life of George L. Jackson - a writer, political theorist, and BGF leader - who was shot dead by prison guards while imprisoned at San Quentin. This note will provide a detailed review of the gang validation process, some of the current problems faced by Black inmates facing gang validation, and the constitutional issues at stake under current CDCR gang policies. Finally this note will recommend legal and policy changes to improve the CDCR's treatment of Black inmates and to bring the gang validation process within constitutional bounds.

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