Morales v. Department of Corrections
- Valerie Caproni
- 1:20-cv-10126
- U.S. District Court · Southern District of New York
- 3
In Morales v. Brann, Judge Caproni adopted the recommendation and granted defendants’ summary-judgment motion in full, closing the case.
Jonathan Morales’s constitutional claims concerning COVID-19 conditions at the Vernon C. Bain Center were resolved against him when the court granted Cynthia Brann, Patsy Yang, and Margaret Egan’s motion for summary judgment in full and closed the case.
What happened
Jonathan Morales sued Cynthia Brann, Patsy Yang, and Margaret Egan, alleging that they violated his constitutional rights by failing to adequately reduce the COVID-19 threat while he was held at the Vernon C. Bain Center. Morales was later released, and fact discovery ended before the defendants sought summary judgment.
Morales did not oppose the motion or ask for more time, despite receiving an extension. Magistrate Judge Aaron recommended granting the motion, and neither side objected to that recommendation.
Judge Valerie Caproni found no clear error, adopted the amended recommendation in full, granted the defendants’ motion for summary judgment in full, and closed the case. The order also stated that the lack of objections prevented appellate review of the decision.
The detailed version
- Morales v. Department of Corrections · No. 1:20-cv-10126
- Valerie Caproni
- Jan. 4, 2023
Background
Jonathan Morales filed a second amended complaint against Cynthia Brann, Patsy Yang, and Margaret Egan. The opinion describes Brann as the then-Commissioner of the New York City Department of Correction, Yang as the Senior Vice President of Correctional Health Services, and Egan as the Executive Director of the New York City Board of Correction. Morales alleged that the defendants violated his constitutional rights while he was a pretrial detainee at the Vernon C. Bain Center by failing to adequately mitigate the threat of COVID-19 there.
Morales had initially sued the defendants along with other detainees, but the court severed the matters into separate civil actions. The court later referred Morales’s case to Magistrate Judge Aaron for pretrial management and reports and recommendations on dispositive motions. The opinion states that Morales was released from custody at some point before April 14, 2021, was detained again at a different facility around April 2022, and that fact discovery ended on March 15, 2022.
Motion and recommendation
On June 30, 2022, the defendants moved for summary judgment. Summary judgment is a decision ending a claim when the governing legal standard permits judgment without a trial. Morales did not oppose the motion or request an extension, even though the court had given him an extension. On December 15, 2022, Magistrate Judge Aaron issued an amended report and recommendation recommending that the defendants’ motion be granted.
The amended report explained that the parties had fourteen days to file written objections and warned that failing to object would waive objections and prevent appellate review. Neither party filed objections. Because there were no objections, Judge Caproni reviewed the amended report for clear error, meaning an obvious mistake apparent from the record.
Ruling
Judge Valerie Caproni found no clear error in the amended report and recommendation. She adopted it in full, granted the defendants’ motion for summary judgment in full, and closed the case. She also ordered the Clerk of Court to terminate all open motions and close the case. The order stated that, because the parties had received adequate warning, their failure to object precluded appellate review of the decision.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.