On August 10, 1977, in what was the first major "totality of conditions" case outside the South (Palmigiano v. Garrahy), the Honorable Raymond J. Pettine, then Chief Judge of the Federal District Court for Rhode Island, found that the conditions in Rhode Island's prisons "do not provide [a] tolerable living environment" and "would shock the conscience of any reasonable citizen who had a first hand opportunity to view them."