Case: Langley v. Coughlin

On July 31, 1984, female inmates at the Bedford Hills Correctional Facility filed a class-action lawsuit under 42 U.S.C. 1983 against the New York State Department of Corrections and several individual defendants (including the Unit Chief, the Chief of Mental Hygiene, the Superintendent of BHCF, the Fire Safety Officer, and the Deputy Superintendent for Programs) in the U.S. District Court for the Southern District of New York. The plaintiffs, represented by Prisoners' Legal Services of New York City, were a group of women (many of whom were mentally ill) in solitary confinement at the Bedford Hills Special Housing Unit. The mentally ill plaintiffs alleged that their constitutional rights had been violated by a lack of mental health care. Those plaintiffs not suffering from chronic mental illness alleged that the conditions of their confinement subjected them to cruel and unusual punishment. Specifically, they complained that they had been subjected to noxious odors, noise, and danger as the mentally ill women engaged in acts of self-destruction, arson, and assaultive behavior. Several mentally ill women routinely spread feces and urine throughout the unit, flooded the unit with sewerage, and yelled and screamed day and night. The plaintiffs asked the court for declaratory and injunctive relief, as well as damages.

On July 23, 1987, the U.S. District Court for the Southern District of New York (Judge Leonard B. Sand) entered a consent decree between the plaintiffs and the Department of Corrections. The decree provided that inmates must have access to clinical mental health care facilities and treatment, that Bedford Hills would have a qualified mental health professional present to treat inmates five days per week and for at least ten hours per week, that mental health records would be regularly and confidentially kept for each inmate, that the Bedford Hills staff must be annually trained on dealing with mental health issues, that each inmate placed in the Special Housing Unit would receive a mental health evaluation within one day of their entry into the Unit, that the defendants would develop and implement a treatment plan for mentally ill inmates, and that compliance with the decree would be monitored.

The plaintiffs continued their case in court, however, against the individual defendants, asking the court for injunctive relief and damages for their alleged injuries. The defendants asked the court to dismiss the case, claiming that they were protected by qualified immunity. On March 31, 1989, the district court (Judge Sand) denied the defendants' motion for summary judgment, ruling that the correctional authorities responsible for designing and implementing inmate programs were not entitled to qualified immunity against the plaintiffs' claims. Langley v. Coughlin, 709 F.Supp. 482 (S.D.N.Y. 1989).

The Chief of Mental Hygiene at Bedford Hills (a defendant) then brought a cross claim against the New York Office of Mental Health and the other defendants. All defendants again moved for summary judgment, dismissal, or class decertification. On June 8, 1989, the district court (Judge Sand) held that: 1) triable issues of fact existed as to whether the living conditions fell below the constitutionally permissible standard; 2) triable issues of fact existed as to whether there had been inadequate medical care for the serious needs of the mentally disturbed inmates; 3) triable issues of fact existed as to whether the defendants were personally liable for the unconstitutional practices; 4) the New York Office of Mental Health was immune from the cross claims; 5) class decertification was not warranted; and 6) the plaintiff class would be divided into three subclasses based upon the class members' psychiatric disabilities. Langley v. Coughlin, 715 F.Supp. 522 (S.D.N.Y. 1989).

The defendants appealed the district court's decision, and they asked the court to compel additional production of documents by the class plaintiffs. On June 19, 1989, the district court (Magistrate Judge Michael H. Dolinger) ordered the plaintiffs to produce the inmates' psychiatric records and the record of the prior testimony of one of the expert witnesses, but declined to order the plaintiffs to produce other documents that had been requested. Langley v. Coughlin, 1989 WL 436675 (S.D.N.Y. June 19, 1989).

On October 25, 1989, the U.S. Court of Appeals for the Second Circuit (Judge Edward Dumbauld, Judge Jon Ormond Newman, and Judge Wilfred Feinberg) dismissed the appeal, holding that the availability of official immunity from liability in the case was a question of fact, thus the court lacked interlocutory appellate jurisdiction. Langley v. Coughlin, 888 F.2d 252 (2nd Cir. 1989).

On December 21, 1989, the district court (Judge Sand) entered a consent decree between the plaintiffs and all remaining defendants. The decree provided for establishment of a settlement fund of $350,000.00, which was to be distributed amongst the plaintiff class based upon each member's subclass membership and number of days of confinement to the Special Housing Unit during the period in question. The approximate disbursement was expected to be as follows: members of Subclass I were to be paid $36.00 per day of confinement, members of Subclass II were to receive $9.00 per day of confinement, and members of Subclass III were to receive $6.00 per day of confinement.

Our docket records end at June 27, 1989, thus we have no further information on the proceedings in this case.