Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1 :05-cv-00823-SLR—LPS Document 261 -3 Filed 05/19/2008 Page 1 of 3 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GEORGE A. JACKSON, et al., )
Plaintiffs, g I
v. g C. A. N0. 05-823-SLR -
STANLEY TAYLOR, et al., g J URY TRIAL REQUESTED
Defendants. g p
AFFIDAVIT OF TREATMENT _
ADIVIINISTRATOR PATRICIA DITTO
I, Patricia Ditto, having been duly sworn by law, do hereby depose and state as
follows:
1. I am employed by the State of Delaware Department of Correction
(“DOC") as the Correctional Treatment Administrator at the Sussex Correctional
Institution ("SCI"). I have been employed by the DOC since March 1980, and have held A
the position of Treatment Administrator since January 1, 2000. As Treatment i
Administrator, my duties include supervision of SCI counseling staff, classification staff,
recreation staff, law library staff and administrative specialists.
2. SCI houses an all-male population of medium, and minimum security
inmates. There are several programs at SCI designed to facilitate inmate rehabilitation.
These programs include educational opportunity, vocational training, work assignments,
and a variety of other classes and programming.
3. At SCI, inmates can be classified to several different jobs during their _
period of incarceration. Some examples include woodshop worker, educational tutor (for l
inmates taking their GED examinations), janitor, laundry worker, and groundskeeper. `
E

Case 1:05-cv-00823-SLR—LPS Document 261-3 Filed 05/19/2008 Page 2 of 3
4. Inmate workers at SCI are paid a nominal salary for each hour they are
employed. While some inmates may prefer outside work as a groundskeeper or in the
woodshop, these jobs are assigned based upon the inmate’s good behavioral records,
proper classification (i.e., security risk), and demonstrated trustworthiness. Some jobs
permit inmates to develop vocational skills they can apply towards a career upon their (
release from the DOC.
5. Inmates are not "forced" to work at a job. As stated above, if inmates are
assigned to jobs in the prison, they are paid for their time. Otherwise, they are required to
participate in other programs at SCI (such as an educational program), as part of their
rehabilitation. An inmate is not permitted to serve a term of incarceration without
entering into an educational program or treatment program, as this runs contrary to the
rehabilitative goals of the DOC.
6. Many inmates are employed in the SCI kitchen, in part because there are
more opportunities to work in this vocation (i.e., more staff is required to run the SCI
kitchen than, for example, needed as educational tutors), and because of the modest
1
qualifications required. Inmates residing in the Medium Building of SCI work at the
SCI kitchen, because their classification levels (which lead them to be assigned to either
of these two buildings in the first place) meet the standards for kitchen jobs.
7. Plaintiff George Jackson was classified out ofthe kitchen and into the
laundry on July I0, 2006. On September I7, 2007, Jackson was classified out of laundry R
and into education as an education tutor.
8. I have made these statements based upon my personal knowledge,
specialized training, and experience as an employee of the Department of Correction.
l

0 Case 1 :05-cv-00823-SLR—LPS Document 261 -3 Filed 05/19/2008 Page 3 of 3
1
Patricia Ditto `
SWORN AND SUBSCRIBED before me this {Q day of May, 2008.
Nutauy és. L’;' {
. SHAHDNA. BUSS Q -" 3 V-
Notary Public. Stats of Dalmnnra A _ j
My Ccmmisslun Exbirss May 21. 2009
1
I
i
1