Davidson v. Department of Corrections
- Lorna Schofield
- 1:20-cv-09500
- U.S. District Court · Southern District of New York
- 2
In Davidson v. Department of Corrections, Judge Schofield denied Willet Davidson’s request for immediate relief because his transfer eliminated an imminent injury at the facility.
Willet Davidson, who was representing himself in claims concerning conditions at the Vernon C. Bain Center; the order denied his requested injunctive relief and appeal fee waiver.
What happened
In Davidson v. Department of Corrections, Willet Davidson, who was representing himself, asked the court for immediate relief based on conditions at the Vernon C. Bain Center. He sought release from custody because of COVID-19 risks, limits on the facility’s population, social distancing, and damages.
The court treated Davidson’s request as a motion for a preliminary injunction, which is an order providing immediate protection from a serious and imminent harm. The court said an injunction could not award monetary damages and noted that Davidson had been transferred from the Vernon C. Bain Center to another facility that defendants said they did not control.
Judge Lorna G. Schofield denied Davidson’s requests for injunctive relief because he could not show an imminent injury from conditions at the Vernon C. Bain Center. The court also denied fee-waiver status for an appeal after certifying that an appeal would not be taken in good faith.
The detailed version
- Davidson v. Department of Corrections · No. 1:20-cv-09500
- Lorna Schofield
- June 7, 2021
Background
Willet Davidson, proceeding without a lawyer, filed a Second Amended Complaint alleging violations identified in the opinion as arising under 19 U.S.C. § 1983. The claims concerned conditions of confinement at the Vernon C. Bain Center. Davidson requested release from custody because of COVID-19 risks, a limit of 50% of the center’s capacity, enforcement of social distancing, and damages.
Davidson later filed a letter asking the court to immediately grant the relief requested in his complaint. The court treated that letter as a motion for a preliminary injunction, meaning a request for immediate court-ordered protection before the case is finally resolved.
Reasoning
The court explained that a preliminary injunction is available only for irreparable harm—an actual and imminent injury that money damages cannot remedy. The court therefore stated that an injunction could not be used to grant monetary damages.
The court also relied on public records showing that Davidson had been transferred on May 26, 2021, from the Vernon C. Bain Center to Downstate Correctional Facility. Defendants represented that Downstate was not under their control. Because of the transfer, the court concluded that Davidson could not show an imminent injury caused by conditions at the Vernon C. Bain Center that would justify immediate injunctive relief.
Disposition
The court ordered that Davidson’s requests for injunctive relief at Docket Number 13 were denied. The court separately certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-waiver status for purposes of an appeal. The opinion does not rule on the merits of Davidson’s underlying claims for damages or other relief.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.