Williams v. New York State

Background

Alexander Williams, Jr., proceeding without a lawyer, sued the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), the City of New York, and several individuals, alleging constitutional-rights violations at Sing Sing Correctional Facility. In an earlier order, the court dismissed the State of New York and DOCCS under 28 U.S.C. § 1915(e)(2)(B)(iii) and separated Williams’s claims against the City of New York from this case. The remaining defendants were Monifa Jack, Pasko Delovic, Timothy Maid, Vito Marsico, and Bermann Joseph.

The remaining defendants had filed a motion to dismiss Williams’s complaint, which was pending when Williams sought emergency relief. Williams moved for a temporary restraining order and preliminary injunction directing the “new york state prison system” to provide inmates unrestricted access to facility law libraries and visitation, avoid placing inmates in restrictive conditions without due process, and provide daily recreation. He attributed the requested relief to what he characterized as a “strike by thousands of correctional officers” that had allegedly placed Sing Sing in a lockdown-like condition.

Court’s analysis

The court explained that a temporary restraining order and a preliminary injunction are governed by the same standard. Generally, the person seeking an injunction must show likely irreparable harm, a likelihood of success on the merits or sufficiently serious questions for litigation combined with a decisive balance of hardships, and that the injunction would serve the public interest. A mandatory injunction, which requires affirmative action and changes the existing situation, requires an even stronger showing.

The court found that Williams had not shown irreparable harm. Williams argued that denial of law-library access would directly affect his ability to continue litigating this case and a separate state action. But the motion to dismiss in this case was still pending, there were no current court deadlines, and Williams had not identified a pending deadline in the state action. The court therefore concluded that he had not demonstrated actual and imminent harm that could not be remedied later.

The court also found that Williams had not shown a likelihood of success on the merits of the requested injunction. The requested order was directed at the “new york state prison system,” but the State of New York and DOCCS were no longer defendants, and Williams had not named a state official authorized to direct that system. The court concluded that it lacked jurisdiction to enforce the requested injunction against those nonparties.

Disposition

The court denied Williams’s application for a temporary restraining order and preliminary injunction. It separately certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied fee-waiver status for an appeal. The court directed the clerk to mail Williams a copy of the order.