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 adopted a report and granted defendants summary judgment, ending the case.
Willet Davidson and the defendants; the order also concerns the filing under seal of Davidson’s confidential medical records.
What happened
In Davidson v. Department of Corrections, defendants asked for summary judgment on Willet Davidson’s constitutional challenge to the conditions of confinement. They also asked to file exhibits containing Davidson’s confidential medical information under seal.
Magistrate Judge Stewart D. Aaron recommended granting the defendants’ motions, finding insufficient evidence of deliberate indifference, another culpable mental state, individual actions by the defendants, or exhaustion of administrative remedies. No timely objections were filed.
Judge Lorna G. Schofield found no clear error, adopted the report in full, granted summary judgment to the defendants, and directed the Clerk of Court to terminate the case. The court also adopted the recommendation to grant the motion to seal Davidson’s medical records.
The detailed version
- Davidson v. Department of Corrections · No. 1:20-cv-09500
- Lorna Schofield
- Jan. 31, 2023
Background
Willet Davidson brought a constitutional claim challenging the conditions of confinement. On April 14, 2022, the defendants moved for summary judgment, which asks the court to resolve a claim without a trial when the record does not show enough evidence for the opposing party to prevail. The defendants also moved to file exhibits containing Davidson’s confidential medical information under seal.
The court had referred the summary-judgment motion to Magistrate Judge Stewart D. Aaron for a report and recommendation. Judge Aaron’s amended report recommended granting the defendants’ motions. The report identified insufficient evidence of deliberate indifference or another culpable mental state, evidence the report said was necessary to prevail on the constitutional conditions-of-confinement claim. It also identified insufficient evidence concerning the defendants’ individual actions and exhaustion of administrative remedies. The report separately recommended granting the motion to seal Davidson’s medical records.
Review and Ruling
The report was mailed to Davidson on December 16, 2022, and objections were due December 30, 2022. No timely objections were filed. Because there were no timely objections, Judge Schofield reviewed the record for clear error rather than conducting a fresh review of the disputed issues. She found no clear error and adopted the report in full.
The court granted summary judgment to the defendants. It also adopted the report’s recommendation to grant the motion to seal Davidson’s medical records. The Clerk of Court was directed to close the motion at Docket 55 and terminate the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.