Filed Date: Oct. 4, 2013
Case Ongoing
Clearinghouse coding complete
On October 4, 2013, a death row inmate at the Connecticut Northern Correctional Institution (NCI) filed this lawsuit pro se in the U.S. District Court for the District of Connecticut. The plaintiff sued the commissioner of the Connecticut Department of Corrections and six other state officials in their official and individual capacities under 42 U.S.C. § 1983 and the Americans with Disabilities Act (ADA). The plaintiff sought declaratory and injunctive relief, including a release from 23 hour-per-day solitary confinement, an end to universal use of restraints while outside of his cell, access to group religious services, visitation rights, a return of private property, and mental health care. The plaintiff also sought monetary compensation and damages. Specifically, the plaintiff claimed that the defendants violated his Fifth, Eighth, and Fourteenth Amendment rights, as well as the Constitution’s Article I Section 10 Ex Post Facto and Bill of Attainder clauses, and the 1949 Geneva Convention prohibition on collective punishment.
The plaintiff had originally been sentenced to death and served 21 years on death row. After the state abolished capital punishment in 2015, he was re-sentenced to life in prison without the possibility of parole in 2017 (during this litigation). Throughout the 23 years of his sentence prior to the time of filing, the plaintiff lived in a 12x7 foot concrete cell with only a three-inch wide window. He spent between 22 and 23 hours every day in this cell. He had extremely limited contact with other prisoners and was handcuffed or shackled whenever he left his cell. He sought injunctive relief to order the state to release him from solitary confinement and place him in the general prison population, to pay back wages, to allow group Seventh Day Adventist religious services, to return all personal property, to stop the elevated uses of restraints, to improve mental health care, to provide better access to recreation and dining facilities, to restore his security levels and accompanying privileges to his pre-2017 status, to end collective punishments, and to end discrimination against life-term inmates.
The case was assigned to Judge Stefan R. Underhill. In 2014, the case was referred to Magistrate Judge William I. Garfinkel for settlement conferences.
On March 3, 2015, the defendants moved for summary judgment. The defendants first claimed that they were immune in their official capacities from money damages under the Eleventh Amendment, and second that they were entitled to qualified immunity in their individual capacities. They also argued that the conditions on death row were constitutional and satisfied the Eighth Amendment. But before the court ruled on the motion or the plaintiff even replied, a clinical professor at Columbia University School of Law was appointed as pro bono counsel for the plaintiff. The motion was denied as moot and the plaintiff was given the opportunity to amend his complaint with new counsel. After multiple extensions were granted, the plaintiff filed an amended complaint on June 30, 2017.
The plaintiff alleged in the amended complaint that state statutes transferring former death row prisoners to solitary confinement unconstitutionally amounted to bills of attainder and ex post facto laws. The complaint also dropped claims of Fifth Amendment and Geneva Convention violations. The plaintiff still sought a permanent injunction, requesting that the defendants submit a plan to the court to release him from solitary confinement, provide mental health care, end his physical and social isolation, and end his sensory deprivation.
After over a year of discovery, the parties filed cross-motions for summary judgment on November 9, 2018. On August 27, 2019, Judge Stefan Underhill granted the plaintiff’s motion and denied the defendants’ motion. Judge Underhill found that the conditions of confinement violated the plaintiff’s Eighth Amendment right to be free from cruel and unusual punishment because they were deliberately indifferent to the serious risks of the plaintiff's confinement. The court also found that the defendants violated the plaintiff's Fourteenth Amendment rights to due process and equal protection. Furthermore, Judge Underhill found that the state's statute on death row was an unconstitutional bill of attainder in violation of Article I Section 10 of the Constitution. Judge Underhill granted permanent injunctive relief to the plaintiff. 402 F.Supp.3d 3.
In a separate injunctive and declaratory relief order, the court ordered the state to end plaintiff’s placement in the high security confinement, to allow the plaintiff to leave his cell for more than four hours per day, and to stop his segregation from other prisoners. The court also ordered that the state provide a “meaningful individualized classification determination“ for the plaintiff's security level every six months. The state was also ordered to stop enforcement of the death row "special circumstances" policy against any current or future prisoner. Finally, the court ordered the state to submit a status report within 30 days detailing how these orders would be effectuated.
On September 4, 2019, Judge Underhill granted in part the defendants’ motion to stay his order, but denied the defendants’ request to stay the requirement of a 30-day status report. Five days later, on September 9, the defendants appealed the court's order granting summary judgment to the U.S. Court of Appeals for the Second Circuit (Docket No. 19-2858).
On September 20, 2019, the defendants moved to stay proceedings in the district court pending their appeal to the Second Circuit. On September 25, 2019, another prisoner held under the state "special circumstances" statute on death row filed a motion to intervene, seeking to oppose the stay of the injunction. The defendants filed a status report that same day. On October 16, 2019, the district court granted the stay as to determining damages but denied the stay as to enforcing injunctive relief. However, the Second Circuit issued a temporary stay on injunctive relief on November 1, 2019. On January 7, 2020, a three judge panel stayed proceedings pending the defendants’ appeal.
On March 11, 2021, the Second Circuit issued its opinion, affirming in part and vacating in part the district court’s grant of summary judgment for the plaintiff and issuance of a permanent injunction. The appellate court held that the district court had erred by deciding disputed issues of material fact going to the plaintiff’s Eighth Amendment and Due Process claims. Specifically, the district court erred in finding that the precise conditions imposed in the Special Circumstances Unit in which Reynolds was housed were undisputed. This finding had bearing on whether the conditions were properly characterized as “solitary confinement.” The Second Circuit affirmed the lower court’s conclusions on the bill of attainder and Equal Protection issues, and remanded for further proceedings as to whether the district court’s injunction violated the Prison Litigation Reform Act (PLRA), whether the defendants were entitled to qualified immunity, and the existence of Eighth and Fourteenth Amendment Due Process violations. 990 F.3d 286.
On December 6, 2021, the plaintiff moved to consolidate this case with Webb v. Semple, 3:17-cv-01623; Campbell v. Maldonado, 3:19-cv-01430; and Campbell v. Lantz, 3:19-cv-01512, but the court denied the motion on February 3, 2022.
The parties prepared for trial, filing a joint pretrial memo on August 12, 2022, then engaging in evidentiary disputes, before jury selection began on September 7, 2022. Along with the pretrial memo, the defendants also moved to dismiss the plaintiff’s claims for declaratory relief. They argued that the plaintiff’s claims were barred by the Eleventh Amendment because the plaintiff was no longer on Special Circumstances status, so any declaratory relief would have been retroactive, and the defendants were entitled to Eleventh Amendment immunity. The court agreed with the defendants and granted this motion on November 4, 2022.
On November 22, 2022, the court ordered supplemental briefing on three issues: the applicability of the subjective prong, or the deliberate indifference requirement, to the case given that the conditions of the plaintiff’s confinement were at least partially imposed by statute; whether the Eighth Amendment requires or permits conditions of confinement to be proportionate to the sentence imposed; if the Eighth Amendment so requires or permits, in the case of an individual sentenced to death, whether that death sentence alone can justify conditions of confinement not based on ordinary classification factors.
A jury trial began on December 6, 2022. On December 15, 2022, the jury returned a verdict in favor of the plaintiff, finding that the defendants had violated the plaintiff’s Fourteenth Amendment Due Process rights from May 2017 through August 2019, and awarded the plaintiff nominal damages of $3. The jury also awarded nominal damages of $1,719.98 for violations of the plaintiff’s Fourteenth Amendment Equal Protection rights. The court had previously granted summary judgment on that issue to the plaintiff, and the judgment was affirmed on appeal before trial. The jury found for the defendants on all other counts. The court entered the judgment on January 10, 2023, and retained jurisdiction to adjudicate any dispute between the plaintiff’s counsel and the plaintiff, arising from his representation.
On January 23, 2023, the plaintiff moved for a new trial. As of December 2023, the case is ongoing in the district court.
Summary Authors
Francis O'Rourke (9/23/2019)
Chelsea Rinnig (1/9/2020)
Kady Matsuzaki (4/30/2023)
Venesa Haska (11/15/2023)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5238552/parties/reynolds-v-arnone/
Garfinkel, William I. (Connecticut)
Dignam, Brett (Connecticut)
Finn, Tyler M (Connecticut)
Belforti, James Michael (Connecticut)
Barrett, Christopher M. (Connecticut)
See docket on RECAP: https://www.courtlistener.com/docket/5238552/reynolds-v-arnone/
Last updated March 22, 2025, 12:09 p.m.
State / Territory:
Case Type(s):
Special Collection(s):
Multi-LexSum (in sample)
Solitary confinement
Key Dates
Filing Date: Oct. 4, 2013
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Individual prisoner in solitary confinement.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: Yes
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Commissioner of Connecticut Dept. of Corrections, State
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Due Process: Procedural Due Process
Other Dockets:
U.S. Court of Appeals for the Second Circuit 19-02858
District of Connecticut 3:13-cv-01465
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Content of Injunction:
Amount Defendant Pays: 1,722
Issues
General/Misc.:
Sanitation / living conditions
Disability and Disability Rights:
Jails, Prisons, Detention Centers, and Other Institutions:
Solitary confinement/Supermax (conditions or process)
Medical/Mental Health Care: