Case: Wilson v. Beame

1:74-cv-00208 | U.S. District Court for the Eastern District of New York

Filed Date: 1974

Clearinghouse coding complete

Case Summary

In 1974, the plaintiffs in this case––nine individuals formerly or presently held at the Brooklyn House of Detention for Men––filed this case in the U.S. District Court for the Eastern District of New York. Suing under 42 U.S.C. §1983, the plaintiffs made a pair of constitutional due process violations regarding their alleged arbitrary placement into administrative segregation and the differentiated treatment they received as persons in administrative segregation compared to other detained pers…

In 1974, the plaintiffs in this case––nine individuals formerly or presently held at the Brooklyn House of Detention for Men––filed this case in the U.S. District Court for the Eastern District of New York. Suing under 42 U.S.C. §1983, the plaintiffs made a pair of constitutional due process violations regarding their alleged arbitrary placement into administrative segregation and the differentiated treatment they received as persons in administrative segregation compared to other detained persons not so placed. Represented by the Legal Aid Society of New York City, the plaintiffs sought injunctive relief against New York City, its Department of Corrections, and relevant officials.

On June 7, 1974, the court granted in part and denied in part as moot the plaintiffs' motion for a preliminary injunction. 380 F. Supp. 1232. As to the plaintiffs' administrative segregation argument, the court found that some of the plaintiffs had since been released. As to the still-detained plaintiffs, the court found that they had attempted to escape and that their trials on those escape charges afforded them sufficient due process protections to ensure they would not unreasonably be placed in administrative segregation. The court did, however, hold that individuals in administrative segregation could not be treated differently from people in the general detention population with respect to at least a few services that were available to members of the broader jail population. Specifically, the court ruled that people held in administrative segregation were unconstitutionally deprived of access to religious services, legal assistance, and educational programs. The court did not rule that administrative segregation was per se impermissible, finding that there were constitutionally permissible purposes for such a classification, even for pre-trial detained persons.

The remainder of the case and its documents is unavailable to the Clearinghouse.

Summary Authors

Matthew Feng (5/26/2023)

Documents in the Clearinghouse

Document

1:74-cv-00208

Memorandum of Decision and Order

June 7, 1974

June 7, 1974

Order/Opinion

Docket

Last updated Aug. 30, 2023, 2:55 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: New York

Case Type(s):

Jail Conditions

Key Dates

Filing Date: 1974

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

Nine presently or formerly detained persons at the Brooklyn House of Detention for Men

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Legal Services/Legal Aid

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

New York City Department of Corrections (New York, Kings), City

Defendant Type(s):

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Due Process: Substantive Due Process

Cruel and Unusual Punishment

Available Documents:

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1974 - None

Content of Injunction:

Preliminary relief granted

Issues

General:

Access to lawyers or judicial system

Administrative segregation

Conditions of confinement

Disciplinary segregation

Religious programs / policies

Type of Facility:

Government-run