Allen v. New York State Department of Corrections and Community Supervision

Background

The court reviewed the parties’ submissions about whether it had jurisdiction over the plaintiffs’ order to show cause. The request was directed to Cathy Sheehan, identified as Deputy Commissioner and Counsel for the New York State Department of Corrections and Community Supervision (DOCCS), and Matthew D’Amore, identified as Superintendent of Marcy Correctional Facility. The request concerned the plaintiffs’ access to their attorneys.

The underlying complaint sued Dr. Moores in her official capacity based on claims of deliberate indifference in violation of the Eighth Amendment. The order to show cause, however, concerned access to counsel and was directed at Sheehan and D’Amore, who were not parties to the litigation.

Jurisdictional Arguments

The plaintiffs offered three proposed bases for jurisdiction.

First, they argued that because they sued Dr. Moores in her official capacity, the lawsuit was effectively against DOCCS and therefore the court had jurisdiction over claims involving Sheehan and D’Amore as DOCCS employees. The court stated that, even assuming this argument was correct, it would not establish jurisdiction over the alleged conduct of those employees. The court explained that injunctive relief must relate to the claims and defendants in the complaint. Because the request involved access to counsel rather than the deliberate-indifference claims against Dr. Moores, and because it was directed at non-parties, the court rejected this basis.

Second, the plaintiffs argued that the court had inherent authority—the court’s power to manage and enforce its proceedings—to order their access to their attorneys. The court found that the cases the plaintiffs cited concerned dismissal for failure to prosecute, discovery sanctions, and enforcement of protective orders. None addressed whether a court could use inherent authority to order a non-party prison official to provide a prisoner access to an attorney. The court therefore rejected this basis as well.

Third, the plaintiffs relied on the All Writs Act, a federal statute allowing courts to issue extraordinary orders necessary or appropriate to support their jurisdiction. The court explained that this authority generally cannot be used when another adequate legal remedy is available. It found that the plaintiffs could bring a new lawsuit against Sheehan and D’Amore for any violations of their rights to counsel and access to the courts. The availability of that alternative remedy defeated the plaintiffs’ All Writs Act argument.

Ruling

The court dismissed the plaintiffs’ order to show cause for lack of jurisdiction. The opinion did not resolve the merits of the plaintiffs’ underlying claims or determine whether their access-to-counsel rights had been violated.