Case: Monmouth County Correctional Institution Inmates v. Lanzaro

2:82-01924 | U.S. District Court for the District of New Jersey

Filed Date: June 15, 1982

Closed Date: April 13, 1989

Clearinghouse coding complete

Case Summary

In 1982, various pro se inmates filed lawsuits in the United States District Court for the District of New Jersey against county and state officials regarding conditions in the Manmouth County Correctional Institute (MCCI) in New Jersey. On January 4, 1983, the district court consolidated the lawsuits. Plaintiffs were represented by the Department of the Public Advocate. The court referred the matter to a special master, James R. Zazzali, to investigate conditions at MCCI. The Master's repo…

In 1982, various pro se inmates filed lawsuits in the United States District Court for the District of New Jersey against county and state officials regarding conditions in the Manmouth County Correctional Institute (MCCI) in New Jersey. On January 4, 1983, the district court consolidated the lawsuits. Plaintiffs were represented by the Department of the Public Advocate. The court referred the matter to a special master, James R. Zazzali, to investigate conditions at MCCI. The Master's report concluded that the conditions were unconstitutional and on October 10, 1984, the court (Judge Harold A. Ackerman) ordered a population limit of 344 inmates in MCCI, an increase in visitation hours, one hour of recreation per day for all inmates, and medical screening prior to release for all inmates. Monmouth County Corr. Inst. Inmates v. Lanzaro, 595 F.Supp. 1417 (D.N.J. 1984).

In January of 1985, plaintiffs sought preliminary injunctive relief from deficiencies in meeting the health needs of pregnant inmates. The parties entered into a consent judgment, but inmates again filed a lawsuit after they were unable to obtain services related to the termination of pregnancies. MCCI had a policy of only providing abortions in life-threatening situations. Some inmates were allowed to leave the facility after obtaining a court-ordered release to personally arrange an abortion. Inmates incarcerated on serious charges were not permitted to leave and were forced to carry pregnancies to term. Plaintiffs challenged the requirement of getting a court order as an infringement of their right to privacy. On June 30, 1986, the court (Judge Ackerman) found the policy unconstitutional. Monmouth County Corr. Inst. Inmates v. Lanzaro, 643 F.Supp. 1217 (D.N.J. 1986). Additionally, the refusal to appropriate funds for non-life-threatening situations violated the New Jersey constitution, although not the federal Constitution. Judge Ackerman ordered the facility to cease its practice of requiring pregnant inmates to seek a court-ordered release, to inform women of their right to continue their pregnancy or obtain an abortion, to provide counseling, to make arrangements necessary to obtain an abortion, to assume the cost of all inmate abortions, and to provide a copy of the order to all pregnant inmates.

Defendants appealed. The United States Court of Appeal for the Third Circuit (Judge A. Leon Higginbotham) affirmed the decision of the district court and modified it in part. Monmouth County Corr. Inst. Inmates v. Lanzaro, 834 F.2d 326 (3d Cir. 1987). The court modified the order so that authorities were not required to make arrangements for an abortion, only provide transportation, and only fund abortions if no other funding is available. The United States Supreme Court denied certiorari on May 16, 1988. Lanzano v. Monmouth County, New Jersey, Corr. Inst. Inmates, 486 U.S. 1006 (1988).

On September 1, 1988, Judge Ackerman modified his 1984 order to reflect improved conditions in the facility as reported by the special master and increased the capacity to 560 inmates. Monmouth County Corr. Inst. Inmates v. Lanzaro, 695 F.Supp. 759 (D.N.J. 1988). Plaintiffs requested a modification to reduce the inmate cap. This was denied. Monmouth County Corr. Inst. Inmates v. Lanzaro, 717 F.Supp. 268 (D.N.J. 1989).

Summary Authors

Angela Heverling (5/9/2006)

People


Judge(s)

Ackerman, Harold Arnold (New Jersey)

Higginbotham, Aloyisus Leon Jr. (Pennsylvania)

Attorneys(s) for Plaintiff

Ayala, Anthony J. (New Mexico)

Bomsey, Audrey (New Jersey)

Boswell, Gerald (New Jersey)

Hanssens, Catherine A. (New Jersey)

Mitchell, T. Gary (New Jersey)

Pori, Brian A. (New Mexico)

Schoenburg, Peter (New Mexico)

Winterbottom, Richard A. (New Mexico)

Judge(s)

Ackerman, Harold Arnold (New Jersey)

Higginbotham, Aloyisus Leon Jr. (Pennsylvania)

Attorneys(s) for Plaintiff

Ayala, Anthony J. (New Mexico)

Bomsey, Audrey (New Jersey)

Boswell, Gerald (New Jersey)

Hanssens, Catherine A. (New Jersey)

Mitchell, T. Gary (New Jersey)

Pori, Brian A. (New Mexico)

Schoenburg, Peter (New Mexico)

Winterbottom, Richard A. (New Mexico)

Attorneys(s) for Defendant

Carton, Malcolm V. (New Jersey)

Maloney, Joseph T. (New Jersey)

Other Attorney(s)

Benshoof, Janet (New York)

Jones, Charles H. Jr. (New York)

Expert/Monitor/Master

Zazzali, James (New Jersey)

Documents in the Clearinghouse

Document

2:82-01924

Opinion

595 F.Supp. 1417, 1984 U.S.Dist.LEXIS 22884

Nov. 14, 1984

Nov. 14, 1984

Order/Opinion

2:82-01924

Opinion

643 F.Supp. 1217, 1986 U.S.Dist.LEXIS 24892

June 30, 1986

June 30, 1986

Order/Opinion

86-05527

Opinion of the Court

U. S. Court of Appeals for the Third Circuit

834 F.2d 326, 1987 U.S.App.LEXIS 15640

Nov. 25, 1987

Nov. 25, 1987

Order/Opinion

87-01431

Memorandum Decision

Lanzaro v. Monmouth County Correctional Institution Inmates

Supreme Court of the United States

486 U.S. 1006, 108 S.Ct. 1731, 100 L.Ed.2d 195

May 16, 1988

May 16, 1988

Order/Opinion

2:82-01924

Opinion

695 F.Supp. 759, 1988 U.S.Dist.LEXIS 10443

Sept. 1, 1988

Sept. 1, 1988

Order/Opinion

2:82-01924

Reported Opinion

717 F.Supp. 268, 1989 U.S.Dist.LEXIS 17270

April 13, 1989

April 13, 1989

Order/Opinion

Resources

Docket

Last updated Aug. 12, 2022, 3:06 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: New Jersey

Case Type(s):

Jail Conditions

Key Dates

Filing Date: June 15, 1982

Closing Date: April 13, 1989

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

Inmates at the Monmouth County Correctional Institution challenging conditions of confinement

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: Yes

Class Action Sought: Unknown

Class Action Outcome: Unknown

Defendants

Monmouth County Correctional Institution (Monmouth), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Due Process: Substantive Due Process

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1984 - None

Issues

General:

Recreation / Exercise

Visiting

Crowding:

Crowding / caseload

Type of Facility:

Government-run