Peoples v. Annucci
- Andrew Carter
- 1:11-cv-02694
- U.S. District Court · Southern District of New York
- 4
In Peoples v. Annucci, Judge Carter denied Amin Booker’s request to undo the settlement judgment because only class counsel could seek enforcement.
Amin Booker and other class members seeking to enforce the settlement directly, because the court said their concerns must go through class counsel.
What happened
Peoples v. Annucci involved a class-action settlement about disciplinary solitary confinement in New York state prisons. Amin Booker, a class member confined at Elmira Correctional Facility, argued that the facility was not following the settlement.
Booker asked the court for relief from the judgment approving the settlement under a federal rule allowing a court to provide relief from a judgment. The defendants argued that the settlement allowed only class counsel to seek formal enforcement.
Judge Andrew Carter denied Booker’s motion. The court said the settlement required individual class members to bring concerns to class counsel, and it said Booker would need to file a separate motion to remove class counsel or a separate complaint about counsel’s conduct.
The detailed version
- Peoples v. Annucci · No. 1:11-cv-02694
- Andrew Carter
- Mar. 30, 2021
Background
The court had certified a class of people serving, or who would later serve, disciplinary confinement in a Segregation Housing Unit or in specified related programs. In March 2016, the court approved a settlement between the plaintiff class and Anthony Annucci, identified in the opinion as the Acting Commissioner of the New York State Department of Corrections and Community Supervision.
The underlying claims alleged that the State’s disciplinary-segregation practices violated the Eighth and Fourteenth Amendments. The settlement provided for reductions in the frequency and length of segregation sentences, improved confinement conditions, and procedures for implementing and enforcing those changes. The court previously found the settlement fair and reasonable.
Booker’s Motion
On March 2, 2020, Amin Booker, a class member, moved under Federal Rule of Civil Procedure 60(b) for relief from the judgment approving the settlement. Booker stated that he had been held in the Segregation Housing Unit at Elmira Correctional Facility since April 22, 2015, and argued that the facility was not complying with the settlement.
The defendants relied on Section XXI of the settlement agreement. That provision states that class members’ complaints or concerns must be referred to class counsel, that the agreement’s enforcement procedures are exclusive, and that only class counsel may seek enforcement or contempt proceedings based on alleged noncompliance.
Court’s Analysis
The court treated the settlement agreement as a binding contract subject to ordinary contract-interpretation principles. Based on the agreement’s plain language, the court held that individual class members who had approved the settlement must go through class counsel to file formal complaints seeking relief from the judgment or enforcement of the judgment’s terms.
The court said class counsel should consider Booker’s concerns in deciding whether a class complaint was justified. It also stated that Booker’s claim had to be dismissed because he could not seek enforcement directly under the agreement.
Disposition
Judge Andrew L. Carter, Jr. denied Booker’s motion. The opinion also states that Booker would need to file a distinct motion if he wanted to remove the New York Civil Liberties Union as class counsel. If he wanted to bring an ineffective-assistance or other claim concerning class counsel, the court said he would need to file an entirely new complaint, either without a lawyer or with independent counsel. The opinion does not state that the denial or dismissal was with or without prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.