Williams v. N.Y.C. Dept. of Corrections
- Lewis Liman
- 1:19-cv-03347
- U.S. District Court · Southern District of New York
- 6
In Williams v. N.Y.C. Dept. of Corrections, Judge Liman denied Alexander Williams’s request for emergency relief because it concerned different events and officers at another facility.
Alexander Williams, a pretrial detainee, whose request for emergency relief was denied; the opinion did not decide the underlying constitutional claims.
What happened
In Williams v. N.Y.C. Dept. of Corrections, Alexander Williams, a pretrial detainee, asked the court for emergency relief based on conditions at the George R. Vierno Center. His earlier consolidated lawsuits concerned alleged misconduct by officers at the Manhattan Detention Center.
Williams’s request described restrictions involving showers, food, religious diet, restraints, commissary access, mail, telephone calls, legal materials, court appearances, and medical care. He argued that these conditions violated his constitutional rights and interfered with his ability to litigate this case and defend his criminal case.
Judge Lewis J. Liman denied the application for a temporary restraining order and order to show cause. The judge ruled that the request concerned different conduct by different officers at a different facility and therefore was outside the court’s jurisdiction in the existing lawsuits; the court did not decide whether the alleged conditions violated Williams’s rights.
The detailed version
- Williams v. N.Y.C. Dept. of Corrections · No. 1:19-cv-03347
- Lewis Liman
- Dec. 3, 2020
Background
Alexander Williams was a pretrial detainee in the custody of the New York City Department of Corrections. Three lawsuits were consolidated. Those complaints alleged that corrections officers at the Manhattan Detention Center, where Williams had been detained during the relevant period, interfered with his outgoing mail, denied him a telephone call with his criminal attorney and access to the law library, ignored grievances, retaliated against him, used chemical spray against him, and denied him adequate medical care. The opinion describes those allegations as involving conduct from January 2019 through July 2020, and later characterizes the consolidated complaints as concerning conduct at the Manhattan Detention Center from January through July 2020.
Williams later informed the court that he had been moved to the George R. Vierno Center. He then applied for a temporary restraining order and an order requiring the defendants to explain why emergency relief should not issue. His application concerned conditions at the new facility in November 2020, including shower access, food preparation, a kosher diet, restraints, sanitation, commissary access, stamps and envelopes, typewriter and other materials, mail handling, calls and visits with his attorney, a court appearance, medication, and a medical examination.
Legal standard
The court explained that a temporary restraining order and a preliminary injunction use the same standard in the Second Circuit. Generally, a person seeking that relief must show a likely success on the merits, likely harm that cannot be repaired without immediate relief, that the balance of hardships favors the requested order, and that the order would serve the public interest.
The court also explained that an injunction is a remedy for a violation alleged in a complaint. It cannot address issues wholly outside the lawsuit, and it generally cannot bind people who are not parties to the case and have not been brought before the court. A complaint must be filed before preliminary emergency relief can be obtained.
Court’s ruling
The court held that it lacked jurisdiction to grant the requested emergency relief. The consolidated complaints involved conduct by officers at the Manhattan Detention Center between January and July 2020. Williams’s application instead concerned different conduct by different officers at the George R. Vierno Center in November 2020. The court therefore concluded that the application was based on matters outside the existing lawsuits.
The court noted that Williams had not filed a request to amend the consolidated complaints to add the later allegations and the additional officers. It also stated that even the allegations most connected to the existing claims—mail handling and a five-day restriction on calling his attorney—would not warrant emergency relief because Williams had not shown likely irreparable harm. The court did not reach the merits of whether the alleged conditions violated his constitutional rights.
Judge Lewis J. Liman denied Williams’s application for a temporary restraining order and order to show cause at docket entries 117 and 118. The Clerk of Court was directed to mail Williams a copy of the order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.