Case: Smith v. Coughlin

1:83-05160 | U.S. District Court for the Southern District of New York

Filed Date: July 12, 1983

Clearinghouse coding complete

Case Summary

A prisoner at Green Haven Correctional facility was convicted of murder and sentenced to death for killing a corrections officer while serving a life sentence. Immediately after sentencing, he was moved from the general prison population to a unit for condemned persons (""UCP""). He then filed a law suit in the U.S. District Court for the Southern District of New York under 42 U.S.C. § 1983 challenging the conditions of his confinement and seeking injunctive relief. Plaintiff was represented…

A prisoner at Green Haven Correctional facility was convicted of murder and sentenced to death for killing a corrections officer while serving a life sentence. Immediately after sentencing, he was moved from the general prison population to a unit for condemned persons (""UCP""). He then filed a law suit in the U.S. District Court for the Southern District of New York under 42 U.S.C. § 1983 challenging the conditions of his confinement and seeking injunctive relief. Plaintiff was represented by William Kunsler, among several other lawyers. Specifically, he alleged violations of his First, Fifth, Sixth, Eighth, and Fourteenth Amendment rights as well as violations of state statute and an existing consent decree.

The district court (Judge David N. Edelstein) ruled against the plaintiff on all but one of his claims. Smith v. Coughlin, 577 F.Supp 1055 (S.D.N.Y. Jan. 6, 1983[sic] ). The court first rejected plaintiff's statutory claim saying that the prison officials' interpretation was reasonable and not clearly erroneous. Next, the court held that plaintiff's Eight Amendment claim was without merit. The court held that the prison has a legitimate interest in restricting plaintiff's visits to family and banning him from group masses. As to the latter, the court specifically held that restriction on attendance in group mass did not infringe on his religious freedom. Additionally, it held that plaintiff had no constitutional right to contact visits, and that alternative means of communication with friends existed. The court also rejected plaintiff's Fifth and Fourteenth Amendment due process claims that he had a protected liberty interest in contact with other inmates that had been deprived without due process of law, reasoning that no such constitutional or state protected interest existed. The claim that the transfer without a hearing violated the consent decree in Kozlowski v. Coughlin, 539 F.Supp 852 (S.D.N.Y. 1982) (PC-NY-034) was also rejected as that order did not apply to prisoners in UCP who have different liberty interests. Plaintiff's equal protection claim was also rejected. Finally, the court rejected the Sixth Amendment claim that the totality of the circumstances diminished his physical and mental health to the point of diminishing his access to courts finding that his will had not been broken. However, the court did find that plaintiff's claim that preventing contact with his paralegals working for his attorneys was meritorious, and the policy did violate his constitutional right to access to the courts.

The Second Circuit (Judge Lawrence Warren Pierce) affirmed and remanded the decision of the district court. Smith v. Coughlin, 748 F.2d 783 (2d Cir. 1984). The court noted, however, that after oral argument, but before its opinion was issued, New York courts had declared as unconstitutional the law under which plaintiff was sentenced to die. Accordingly, plaintiff's sentence was vacated and he was moved from UCP, thus making moot his claims for injunctive relief. The only issue to be resolved was an award of damages, which the court of appeals found the district court had erred in failing to award. The Second Circuit held that although compensatory damages cannot be awarded absent proof of actual compensable injury - which here the plaintiff failed to do - nominal damages could still be awarded. Accordingly, it remanded the case to the district court for entry of a nominal award of $1.

It appears from the timeline that this ruling actually came down on January 6, 1984. We presume that the reporter contains a typo.

The docket for this case is not available on PACER, and therefore our information ends with the Nov. 16, 1984 court opinion.

Summary Authors

Sherrie Waldrup (3/30/2006)

People


Judge(s)

Edelstein, David Norton (New York)

Oakes, James Lowell (Vermont)

Pierce, Lawrence Warren (New York)

Van Graafeiland, Ellsworth Alfred (New York)

Attorneys(s) for Plaintiff

Gombiner, Robert (New York)

Kunstler, William (New York)

Attorneys(s) for Defendant

Abrams, Robert W. (New York)

Bromley, Tarquin Jay (New York)

Butler, Barbara B. (New York)

Howard, Richard M. (New York)

Judge(s)

Edelstein, David Norton (New York)

Oakes, James Lowell (Vermont)

Pierce, Lawrence Warren (New York)

Van Graafeiland, Ellsworth Alfred (New York)

Attorneys(s) for Plaintiff

Gombiner, Robert (New York)

Kunstler, William (New York)

Attorneys(s) for Defendant

Abrams, Robert W. (New York)

Bromley, Tarquin Jay (New York)

Butler, Barbara B. (New York)

Howard, Richard M. (New York)

Leventhal, Melvyn R. (New York)

Documents in the Clearinghouse

Document

1:83-05160

Memorandum Opinion and Order

577 F.Supp. 1055

Jan. 6, 1983

Jan. 6, 1983

Order/Opinion

84-02015

Opinion

U. S. Court of Appeals for the Second Circuit

748 F.2d 783

Nov. 16, 1984

Nov. 16, 1984

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):

Prison Conditions

Key Dates

Filing Date: July 12, 1983

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Condemned prisoner challenging conditions of his confinement in segregated unit for condemned persons

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: Yes

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Green Haven Correctional Facility (Greenhaven), State

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Equal Protection

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1983 - None

Issues

General:

Disciplinary procedures

Disciplinary segregation

Type of Facility:

Government-run