Sughrim v. State of New York
- Ronnie Abrams
- 1:19-cv-07977
- U.S. District Court · Southern District of New York
- 3
In Sughrim v. State of New York, Judge Abrams sought more detail about requested injunctions and stayed the matter pending submissions.
The plaintiffs, defendants, and the court in the action concerning religious beard accommodations for Department of Corrections and Community Supervision officers.
What happened
Officers of New York’s Department of Corrections and Community Supervision challenged the denial of requests to wear beards consistent with their religious beliefs in Sughrim v. State of New York. They asked for several forms of relief, including an order requiring the agency to consider reasonable religious accommodations.
The court explained that an injunction must clearly describe the conduct it requires or forbids and cannot be broader than necessary to address the proven harm. After oral argument, the court concluded that more information about the requested injunctions would help it decide the pending motions.
Judge Ronnie Abrams ordered the plaintiffs to provide more detail by April 14, 2023, and allowed defendants to respond by April 21, 2023. The matter was stayed while the court waited for those submissions; the order did not decide the pending motions.
The detailed version
- Sughrim v. State of New York · No. 1:19-cv-07977
- Ronnie Abrams
- Mar. 31, 2023
Background
Officers of the New York State Department of Corrections and Community Supervision challenged the agency’s denial of requests for accommodations allowing them to wear beards consistent with their religious beliefs. The plaintiffs had pending motions for partial summary judgment, class certification, a declaratory judgment, and injunctive relief. They sought, among other things, an order stopping the agency from denying religious accommodations without showing an undue hardship and requiring it to try to identify reasonable accommodations.
The court held oral argument on March 13, 2023, and focused in part on the scope of the requested injunctions. The plaintiffs later asked the court to set a schedule for the parties to confer about the scope of any injunction or to submit separate proposals if they could not agree.
Court’s Reasoning
The court discussed Federal Rule of Civil Procedure 65(d), which requires an injunction to state the reasons for its issuance, use specific terms, and describe in reasonable detail the acts that are restrained. The court also explained that an injunction should provide no broader relief than necessary to address the harm caused by the violation. An order that merely tells a party to comply with the law may be too vague or broad because it may not identify how the party must change its conduct.
The court stated that the issues and the required assessment of fairness and the public interest made additional submissions about the desired and proper scope of any injunction useful in deciding the pending motions and determining any further relief.
Order and Effect
The court ordered the plaintiffs to provide more clarity about the injunctive relief they sought no later than April 14, 2023. Defendants could file a response by April 21, 2023. Judge Ronnie Abrams ordered that the matter be stayed while the court awaited those submissions. The opinion did not grant or deny the pending motions and did not decide the underlying challenge to the agency’s accommodation decisions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.