Peoples v. Annucci

Background

This class action challenged solitary-confinement practices in facilities operated by the New York State Department of Corrections and Community Supervision. In 2016, the parties entered a settlement agreement under which plaintiffs would monitor compliance through measures including four-day facility tours twice each calendar year, attended by plaintiffs’ expert, and an annual meeting.

The tours and meetings proceeded until the COVID-19 pandemic. The first tour after the pandemic began occurred in September 2021. Plaintiffs sought a one-year extension of the agreement to account for the monitoring time lost because COVID-19 prevented the required in-person visits and meetings.

Motion and parties’ positions

Plaintiffs moved for relief from the settlement judgment under Federal Rule of Civil Procedure 60(b)(5) and (b)(6). They first asked defendants to agree to the extension in March 2021 and renewed that request several times. Defendants initially stated that they did not believe an extension was warranted and offered to schedule additional tours during the existing year. Defendants later agreed to propose the extension but did not provide a response before plaintiffs filed a pre-motion letter.

Rule 60(b)(5) permits a court to relieve a party from a judgment when applying it prospectively is no longer equitable. The motion must be made within a reasonable time. The court also explained that this provision may apply when circumstances beyond the parties’ control, and not contemplated when the judgment was entered, materially change the facts or law.

Court’s analysis

The court found the motion timely even though plaintiffs filed it shortly before the settlement’s monitoring period was set to expire. Plaintiffs had made good-faith efforts for approximately six months to resolve the extension issue without court intervention, and defendants knew that the agreement was nearing termination.

The court also found that the defendants would not suffer significant prejudice. The proposed extension would require the same monitoring process to which defendants had already agreed, for the equivalent one-year period that was missed. COVID-19 was not contemplated when the settlement was entered, was beyond the parties’ control, and materially affected plaintiffs’ ability to perform their monitoring duties.

Disposition

The court granted plaintiffs’ motion for relief from the settlement order under Rule 60(b)(5). It extended the settlement agreement for one year beginning on September 30, 2022. Because the motion was granted under Rule 60(b)(5), the court did not address Rule 60(b)(6). The clerk was directed to terminate the motion at ECF No. 538.