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S.D.N.Y.Procedural orderFiled Feb. 5, 2021

Davidson v. Department of Corrections

Judge
Lorna Schofield
Docket
1:20-cv-09500
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePreliminary InjunctionPro Se
In one sentence

In Davidson v. Department of Corrections, Judge Schofield ordered defendants to respond to Davidson’s COVID-19 relief request and provide medical records.

Who this affects

Willet Davidson, the New York City Department of Corrections and other defendants, the New York City Law Department, Patsy Yang, Cynthia Brann, and Margaret Egan.

What happened

Davidson, an incarcerated person without a lawyer, filed a second amended complaint alleging that inadequate social distancing in his prison dormitory violated the Eighth and Fourteenth Amendments during the COVID-19 pandemic. He requested release, reduced dormitory capacity, social distancing, bed dividers, and damages.

The court understood Davidson’s filings to request release because of COVID-19 risks or, alternatively, a court order requiring safety measures in his dormitory. The order did not decide whether Davidson’s constitutional claims were valid or whether he was entitled to the requested relief.

Judge Lorna G. Schofield ordered the defendants to respond to Davidson’s request by February 16, 2021, and to email his Bureau of Prisons medical records to chambers. The clerk was also directed to notify the New York City Department of Corrections and the New York City Law Department, mail the order to Davidson, and request that three named individuals waive formal service.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Davidson v. Department of Corrections · No. 1:20-cv-09500
Judge
Lorna Schofield
Date
Feb. 5, 2021

Background

Willet Davidson, an incarcerated plaintiff proceeding without a lawyer, filed a Second Amended Complaint against the New York City Department of Corrections and other defendants. He alleged that the lack of social distancing in his prison dormitory during the COVID-19 pandemic violated the Eighth and Fourteenth Amendments.

The Second Amended Complaint requested five forms of relief: release from custody because underlying health conditions allegedly placed Davidson at risk from COVID-19; operation of his dormitory at 50% capacity; enforcement of social distancing; installation of safety dividers between dormitory beds; and damages. Davidson also filed a letter motion asking the court to grant the relief requested in the complaint.

Issues Presented

The court construed Davidson’s filings as seeking either release because of COVID-19 risks or, alternatively, a preliminary injunction. A preliminary injunction is an interim court order directing a party to take or stop taking specified actions while a case continues. Here, the alternative request concerned enforcement of COVID-19 mitigation measures in Davidson’s dormitory.

The order did not decide the merits of Davidson’s constitutional allegations, determine whether release was legally available, or decide whether to issue a preliminary injunction.

Order

Judge Lorna G. Schofield ordered the defendants, by February 16, 2021, to file a response to Davidson’s letter motion under the court’s Individual Rules and to email Davidson’s Bureau of Prisons medical records to chambers.

The clerk was directed to notify the New York City Department of Corrections and the New York City Law Department of the order and mail a copy to Davidson. The court also requested that Patsy Yang, Cynthia Brann, and Margaret Egan waive service of summons. The opinion is an order requiring responses and facilitating service; it does not grant or deny Davidson’s requested release, dormitory measures, or damages.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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