Jackson v. Capra
- Lorna Schofield
- 1:22-cv-03357
- U.S. District Court · Southern District of New York
- 1
In Jackson v. Capra, Judge Netburn told Jackson to bring access claims separately after fully exhausting administrative remedies.
Raphael Jackson, regarding potential claims about access to counsel and the law library.
What happened
Raphael Jackson sent the court a September 20, 2023 letter and referred to an earlier letter that the court had not received. He also submitted grievances alleging that Green Haven Correctional Facility unconstitutionally limited his access to counsel and the law library.
The court said that any challenge to those limits must be brought in a new civil case. It also said Jackson must fully complete the available prison grievance process before filing that case.
Judge Sarah Netburn issued the order on September 26, 2023. The order did not decide whether Jackson’s access claims were legally valid.
The detailed version
- Jackson v. Capra · No. 1:22-cv-03357
- Lorna Schofield
- Sept. 26, 2023
Background
On September 20, 2023, Raphael Jackson filed a letter that the court reviewed. Jackson referred to a September 12, 2023 letter, but the court said it had not received that letter and requested that he submit it again.
Jackson’s September 20 letter included two grievances. In them, he alleged that Green Haven Correctional Facility had unconstitutionally restricted his access to counsel and the law library.
Ruling
The court directed that, to the extent Jackson sought relief concerning those access restrictions, he must pursue that relief in a new civil action rather than in this matter. Before filing the new action, he must fully exhaust his administrative remedies, meaning he must complete the available grievance process. The court cited the Prison Litigation Reform Act’s requirement that an inmate complete available administrative remedies before bringing an action.
The order did not rule on the merits of whether Jackson’s access to counsel or the law library was unconstitutionally restricted. It also did not state that any motion was granted or denied.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.