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S.D.N.Y.Procedural orderFiled July 11, 2023

Williams v. City of New York

Judge
Rearden
Docket
1:22-cv-10537
Court
U.S. District Court · Southern District of New York
Pages
4
Civil ProcedurePreliminary Injunction
In one sentence

In Williams v. City of New York, District Judge Rearden adopted a recommendation denying Williams’s request for emergency and preliminary relief.

Who this affects

Alexander Williams, Jr.’s request for a temporary restraining order and preliminary injunction was denied; the order did not resolve the entire lawsuit.

What happened

In Williams v. City of New York, Alexander Williams, Jr. challenged conditions at the George R. Vierno Center on Rikers Island, including a 23-hour daily lockdown and limited access to religious materials. He asked the court to order an immediate end to the lockdown arrangement.

A magistrate judge reviewed Williams’s request for a temporary restraining order and preliminary injunction and recommended denying it. Williams did not object to that recommendation by the deadline, and he did not ask for more time.

District Judge Rearden reviewed the recommendation and the motion, found no clear error, and adopted the recommendation in its entirety. The order therefore denied Williams’s request for a temporary restraining order and preliminary injunction and directed the clerk to close the related motion entries.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Williams v. City of New York · No. 1:22-cv-10537
Judge
Rearden
Date
July 11, 2023

Background

Alexander Williams, Jr. filed this action in December 2022 while detained at the George R. Vierno Center on Rikers Island and awaiting trial in Kings County Supreme Court. The opinion states that the state court had entered a Judicial Lockdown Order after finding clear and convincing evidence that Williams had solicited other people to threaten, intimidate, and cause serious physical injury or death to witnesses.

Under a command-level order at the detention center, inmates covered by a court-ordered lockdown received 23-hour lock-in and feed-in status. Williams’s lawsuit challenged confinement conditions and an alleged lack of access to religious materials. He moved for a temporary restraining order and preliminary injunction seeking to end the 23-hour lock-in and feed-in status.

Report and Recommendation

The request was referred to Magistrate Judge Aaron. On March 17, 2023, after finding that Williams had not met the standard for an emergency order issued before the defendants appeared, Judge Aaron deferred ruling until after the defendants had appeared. After full briefing, Judge Aaron issued a Report and Recommendation on May 5, 2023, recommending that the motion be denied.

The Report and Recommendation gave the parties fourteen days, until May 19, 2023, to object and warned that failing to object would waive the right to object. Williams filed no objection and did not request an extension.

District Court’s Ruling

District Judge Jennifer H. Rearden explained that, when no timely objection is made, the district court reviews the recommendation for clear error on the record. The court also stated that Williams’s failure to object waived his right to object to the recommendation or obtain appellate review. Despite that failure, the court reviewed the motion and the recommendation and found the recommendation well reasoned and supported by the facts and law.

The court adopted the Report and Recommendation in its entirety, which denied Williams’s motion for a temporary restraining order and preliminary injunction. The clerk was directed to terminate docket entries 6 and 16 and mail Williams a copy of the order. This order addressed the requested interim relief; the opinion does not state that it resolved the entire lawsuit.

The authoritative version

Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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