Reynolds v. Federal Bureau of Prisons
- Nelson Roman
- 7:21-cv-04763
- U.S. District Court · Southern District of New York
- 3
In Reynolds v. Federal Bureau of Prisons, Judge Roman denied Reynolds’s request for court-supervised prison transfer and protection against dismissal.
Brian Edwards Reynolds, a self-represented federal inmate, and the Bureau of Prisons and other defendants involved in the case.
What happened
In Reynolds v. Federal Bureau of Prisons, Brian Edwards Reynolds, a self-represented federal inmate, asked the court to supervise his transfer from FCI Otisville and ensure he could communicate or appear in the case. He also asked the court to reject any defense request to dismiss his lawsuit based on the transfer.
The court denied the motion. It explained that the Bureau of Prisons, not the federal courts, controls inmate placements and transfers. The court also said Reynolds had not shown that he qualified for the extraordinary remedy of a preliminary injunction, and that his allegations did not appear to establish a constitutional or Eighth Amendment violation. His claim that the transfer was approved as part of a plan to obtain dismissal was described as unsupported and conclusory.
Judge Nelson S. Roman entered the order on February 11, 2022. The court reminded Reynolds that he must notify the court of any address change if he is transferred, and directed the clerk to mail him a copy of the order.
The detailed version
- Reynolds v. Federal Bureau of Prisons · No. 7:21-cv-04763
- Nelson Roman
- Feb. 11, 2022
Background
Brian Edwards Reynolds, who was representing himself, told the court that he had been approved for transfer from Federal Correctional Institution Otisville to another facility. He asked the court to supervise the transfer, protect his well-being, and ensure that he remained able to communicate with the court or participate in this case. He also asked the court to be prepared to deny any defense motion to dismiss the lawsuit.
Reynolds alleged that the transfer had been approved unexpectedly so that the defendants could later argue that conditions at Otisville no longer affected his health and seek dismissal. He also feared that the Bureau of Prisons and the United States Marshals Service would not protect him during the transfer and asserted that the approval was retaliatory.
The Government opposed the application. It stated that Reynolds had requested the transfer in October 2021, that he could ask his unit team to stop the transfer if he no longer wanted it, and that it did not intend to rely on the transfer as a basis for its defenses. The Government also argued that the Bureau of Prisons is responsible for inmate placement.
Court’s reasoning
The court treated Reynolds’s request concerning the transfer as a request for a preliminary injunction, meaning an extraordinary court order intended to provide temporary relief before the case is resolved. The court explained that decisions about correctional-facility placement and inmate transfers are under the Bureau of Prisons’ authority, not the control of federal district courts. It concluded that Reynolds had not shown that he was entitled to a preliminary injunction.
The court further stated that Reynolds’s allegations did not appear to reach the level of a constitutional violation, including a violation of the Eighth Amendment. It also found that his assertion that the transfer was part of a plan to obtain dismissal was conclusory and unsupported. The Government’s statement that it did not intend to rely on the transfer as a defense also weighed against that concern.
Disposition
The court denied Reynolds’s requests and denied the motion. It reminded him that he was responsible for notifying the court of any address change if he was transferred. The clerk was directed to mail him a copy of the order and record service on the docket.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.