Medina v. New York City Department of Corrections
- Katherine Failla
- 1:20-cv-03985
- U.S. District Court · Southern District of New York
- 4
In Medina v. New York City Department of Correction, Judge Failla ordered updates on lighting accommodations and law-library access.
Anthony Medina and the defendants, who were required to provide the ordered status updates; the court also referred to the health and safety of other inmates and staff.
What happened
In Medina v. New York City Department of Correction, Anthony Medina raised concerns about access to the North Infirmary Command law library, his legal files, and accommodations while detained there. Some earlier problems had been addressed, including his return to the facility and restored access to legal materials.
Medina newly requested a cell with reduced lighting and said that limiting his law-library access to two days a week was retaliatory. The defendants attributed the library limits to health risks from the COVID-19 pandemic, but had not provided enough information for the court to determine whether Medina's access differed from other inmates' access.
Judge Katherine Failla did not order unrestricted law-library access at that time. She ordered the defendants to report by August 28, 2020, on the reduced-lighting request and by September 4, 2020, on the facility's law-library access policies and procedures.
The detailed version
- Medina v. New York City Department of Corrections · No. 1:20-cv-03985
- Katherine Failla
- Aug. 24, 2020
Background
Anthony Medina sent the court letters dated August 13 and June 9, 2020. He raised issues involving access to the North Infirmary Command law library, legal documents, and accommodations, as well as alleged transfers between facilities intended to deprive him of those resources. The court stated that several of those issues had been addressed: Medina had been returned to the North Infirmary Command, had access to its law library and related accommodations, and had regained access to his legal documents.
Outstanding requests
The court identified two unresolved matters. First, Medina requested a new accommodation: housing in a cell with reduced lighting. He had not requested that relief in his earlier request for an order to show cause or in his motion for a temporary restraining order and preliminary injunction. Because the defendants had not yet had an opportunity to respond, the court ordered them to provide a status update by August 28, 2020, stating their position on the request and describing any changes in how the accommodation was being provided.
Second, Medina alleged that the defendants continued to restrict his access to the law library, legal files, and accommodations by allowing access only two days each week. The defendants had said that library access was limited because of the serious health risks posed by the COVID-19 pandemic. The court declined, at that time, to order unrestricted access because it would not risk the health and safety of Medina, other inmates, and staff. The court stated that access comparable to that provided to other inmates would be sufficient, but it could not determine whether Medina was being treated differently because the defendants had not provided concrete information about other inmates' access.
Ruling and effect
The order required the defendants to report by September 4, 2020, on the North Infirmary Command's formal or informal policies and procedures for inmate access to and use of the law library, legal files, and related accommodations. The order did not decide whether Medina's library access was being restricted in retaliation for his litigation. It also did not decide the merits of his reduced-lighting accommodation request. This was an interim procedural order concerning the court's handling of his requested temporary relief.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.