Filed Date: Sept. 9, 1985
Closed Date: 1994
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On Sept. 9, 1985, inmates at the Trenton State Prison in New Jersey filed this lawsuit, pro se, under 42 U.S.C. §1983 against the New Jersey Department of Corrections in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for injunctive relief, alleging that the prison's legal assistance program was inadequate and denied them access to the courts.
The district court (Judge Robert E. Cowen) granted injunctive relief to the plaintiffs, and the defendants appealed. On June 20, 1988, the U.S. Court of Appeals for the Third Circuit (Judge Carol Los Mansmann) affirmed the district court's decision. Valentine v. Beyer, 850 F.2d 951 (3rd Cir. 1988). On October 4, 2006, the Executive Director of the Inmate Legal Association moved, on behalf of the certified class, to enforce and modify judgments and settlement agreement and to hold defendants in contempt of court, and requested money damages. On April 8, 2008, the court ruled that the action to enforce the settlement agreement was a separate contract dispute, and the proper forum to enforce it was in New Jersey state court, absent an independent basis for federal jurisdiction. The court also stated that likely the proper vehicle to enforce the settlement agreement would be to file a separate action, as opposed to a motion in this closed case.
On October 20, 2009 the Inmate Legal Association did file in state court; the resulting opinion is posted here, and also at Justia.
Summary Authors
Kristen Sagar (2/16/2007)
Abigail DeHart (3/17/2017)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5740260/parties/emmitt-valentine-v-howard-l-beyer/
Cooper, Mary Little (New Jersey)
Mansmann, Carol Los (Pennsylvania)
Campbell, Sarah Brie (New Jersey)
Kahn, Michael E. (New Jersey)
Long, Janine L. (New Jersey)
Cooper, Mary Little (New Jersey)
Mansmann, Carol Los (Pennsylvania)
See docket on RECAP: https://www.courtlistener.com/docket/5740260/emmitt-valentine-v-howard-l-beyer/
Last updated July 11, 2023, 3:03 a.m.
State / Territory: New Jersey
Case Type(s):
Key Dates
Filing Date: Sept. 9, 1985
Closing Date: 1994
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Inmates challenging adequacy of prison's legal assistance program
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: Yes
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Procedural Due Process
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Order Duration: 1988 - None
Issues
General:
Access to lawyers or judicial system
Type of Facility: