Case: Valentine v. Beyer

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.