Case: Vazquez v. Gray

1:78-cv-04914 | U.S. District Court for the Southern District of New York

Filed Date: Oct. 18, 1978

Closed Date: April 13, 2010

Clearinghouse coding complete

Case Summary

In 1979, inmates at the Westchester County Jail filed a class action lawsuit in the U.S. District Court for the Southern District of New York against the Westchester County Department of Corrections under 42 U.S.C. §1983. The plaintiffs claimed that conditions of overcrowding at the jail violated constitutional guidelines and placed a strain on all of the facilities, including medical, food service, law library, and recreation. The plaintiffs sought preliminary injunction concerning these condi…

In 1979, inmates at the Westchester County Jail filed a class action lawsuit in the U.S. District Court for the Southern District of New York against the Westchester County Department of Corrections under 42 U.S.C. §1983. The plaintiffs claimed that conditions of overcrowding at the jail violated constitutional guidelines and placed a strain on all of the facilities, including medical, food service, law library, and recreation. The plaintiffs sought preliminary injunction concerning these conditions.

On September 28, 1981, the court inspected the conditions at WCJ, which housed pretrial detainees. The court (Judge Gerard Louis Goettel) found that the overcrowded conditions violated constitutional guidelines and that the jail limited the inmates' access to recreation areas and other privileges. Vazquez v. Gray, 523 F.Supp. 1359 (S.D.N.Y. 1981). The court noted and defendants conceded that the strained conditions had contributed to riots at the jail in July of 1981. However, the court refused to impose a population limit on the jail and instead issued the following remedies on October 16, 1981:

1.      Prohibited the use of floor mattresses as constitutionally impermissible.

2.      Prohibited the housing of more than two minors in a single cell.

3.      Prohibited housing prisoners in dayrooms for longer than five days.

4.      Limited the use of dormitories to their present and planned uses, finding that the conditions within the dormitories did not amount to a deprivation.

Information regarding the jail's compliance with these remedies is unknown. In 2010, Davis v. Gusman, No. CIVA 09-7195, 2010 WL 1727825 (E.D. La. Apr. 13, 2010) refused to extend the ruling of this case.

Summary Authors

Angela Heverling (2/6/2006)

Richard Jolly (11/4/2014)

People


Judge(s)

Goettel, Gerard Louis (New York)

Attorneys(s) for Plaintiff

Angelos, Claudia (New York)

Berger, Joel (New York)

Greenberg, Jack (New York)

Winter, Steven L. (New York)

Attorneys(s) for Defendant

Slaaten, Marilyn J. (New York)

Yasgur, Samuel S. (New York)

Judge(s)

Goettel, Gerard Louis (New York)

Attorneys(s) for Plaintiff

Angelos, Claudia (New York)

Berger, Joel (New York)

Greenberg, Jack (New York)

Winter, Steven L. (New York)

Attorneys(s) for Defendant

Slaaten, Marilyn J. (New York)

Yasgur, Samuel S. (New York)

Documents in the Clearinghouse

Document

1:78-cv-04914

Opinion

523 F.Supp. 1359, 1981 U.S.Dist.LEXIS 15227

Oct. 16, 1981

Oct. 16, 1981

Order/Opinion

Resources

Docket

Last updated Aug. 12, 2022, 3:10 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: New York

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Oct. 18, 1978

Closing Date: April 13, 2010

Case Ongoing: Perhaps, but long-dormant

Plaintiffs

Plaintiff Description:

inmates at the Westchester County Department of Corrections

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Westchester County Jail (Valhalla , Westchester), County

Defendant Type(s):

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Equal Protection

Due Process

Cruel and Unusual Punishment

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1981 - None

Content of Injunction:

Preliminary relief granted

Issues

General:

Food service / nutrition / hydration

Library (non-law) access

Sanitation / living conditions

Crowding:

Crowding / caseload

Type of Facility:

Government-run