Case: Fields v. Annucci

This putative class action suit, filed by three individuals incarcerated in New York, represented by the New York Civil Liberties Union and Prisoners’ Legal Services of New York, alleged that the New York State Department of Corrections and Community Supervision (DOCCS) was illegally subjecting people to prolonged solitary confinement in violation of the Humane Alternatives to Long-Term Solitary Confinement Act (HALT Act). The case was filed in New York’s supreme court on April 5, 2023, and was assigned to Judge Kevin R. Bryant. Plaintiffs sought declaratory relief along with Article 78 review of the DOCCS policies that allegedly violated the HALT Act. 

The HALT Act, which was passed in 2021 and came into effect in 2022, limited the use of solitary confinement by DOCCS. The Act limited “segregated confinement” (solitary and other in-cell confinement exceeding 17 hours per day) to three consecutive days, or six days in a 30-day period, unless DOCCS determined in writing and pursuant to an evidentiary hearing that the individual to be confined committed one of several specific acts and that the act was “so heinous and destructive” that their presence in general-population housing would pose an unreasonable risk to facility security. If these criteria were met, the limit on “segregated confinement” was 15 consecutive days or 20 days in a 60-day period. At that point, DOCCS would be required to transfer the individual to a Residential Rehabilitation Unit (RRU) if they could not safely return to the general-population housing. 

The complaint alleged that DOCCS had a policy, in violation of the HALT Act, that placed certain individuals in segregated confinement for longer periods of time, for offenses that were not specified in the HALT Act, and without the requisite determination in writing.

On June 23, 2023, DOCCS filed a motion to dismiss, arguing that they were not required to make all findings in writing on the basis that some were “self-evident,” and also that plaintiffs had made a procedural error regarding their prayer for relief in the form of declaratory relief. On September 12, 2023, Judge Bryant denied the motion to dismiss and certified the plaintiff class. The class was defined as “all individuals in DOCCS custody who are or will be placed in segregated confinement for more than three consecutive days, or six days in any 60-day period; a residential rehabilitation unit; or any other unit for which compliance with CL § 137(6)(k)(ii) is required before placement.”

The parties then engaged in a somewhat contentious discovery process, complicated in part by the procedural differences between a declaratory relief claim and an Article 78 review claim. DOCCS submitted an initial administrative record, in response to which, on March 1, 2024, plaintiffs filed a motion requesting the court order DOCCS to submit further information than the initial “insufficient” record for Article 78 proceedings, and later, in April 2024, a request for an order directing discovery for the declaratory action portion of the claim. 

On June 20, 2024, in his decision on the plaintiffs' motions regarding incomplete discovery, Judge Bryant found that, due to the lack of information provided by DOCCS indicating otherwise and based on the record, DOCCS was following a policy in violation of the HALT Act. Judge Bryant declared this policy arbitrary and capricious, as well as a violation of the Halt Act. Judge Bryant ordered DOCCS to comply with the HALT Act by conducting fact-specific inquiries and making specific findings of fact in hearings regarding extended segregated confinement. All previous determinations to place class members in extended segregated confinement made without specific and written findings of fact and conclusions were declared null and void. The pending requests for discovery were dismissed as moot, as the court had granted the relief requested in the complaint. 

The court held its determination of fees in abeyance pending further information from both parties. As of June 2024, the case is ongoing for determination of fees.