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Case Name Vespa v. Board of Freeholders of Burlington County JC-NJ-0005
Docket / Court 77-765 ( D.N.J. )
State/Territory New Jersey
Case Type(s) Jail Conditions
Case Summary
On April 20, 1977, inmates at the Burlington County Jail in Mount Holly, New Jersey, filed lawsuits under 42 U.S.C. §1983 against the county in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for declaratory and injunctive relief, alleging that their ... read more >
On April 20, 1977, inmates at the Burlington County Jail in Mount Holly, New Jersey, filed lawsuits under 42 U.S.C. §1983 against the county in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by overcrowding and inadequate classification procedures at the jail.

The case was eventually consolidated with another case, Morrison v. Brennan, Civ. No. 78-0628, (D.N.J. March 28, 1978). On June 1, 1981, the U.S. District Court for the District of New Jersey (Judge Dickinson R. Debevoise) approved a settlement agreement in the case, providing for population caps, better classification procedures, and renovation of the jail.

Two and a half years later, an inmate named Maurice Scott was being held in an overcrowded cell in violation of the settlement agreement, awaiting his long overdue transfer to state prison. Scott, an inmate known for his violent attacks on other inmates, shared his cell with Timothy Ryan, a pretrial detainee being held for an alleged traffic violation. On October 4, 1983, Scott attacked Ryan, breaking his neck and rendering Ryan a quadriplegic.

In April 1985, Ryan filed a lawsuit under 42 U.S.C. §§ 1983, 1985, and 1988, as well as various state laws, against the New Jersey Department of Corrections and Burlington County in the U.S. District Court for the District of New Jersey. Ryan asked the court for compensatory and punitive damages, alleging that his constitutional rights had been violated by overcrowding, inadequate classification procedures, and failure to protect him from a known violent inmate.

The defendants asked the court to issue summary judgment in their favor and dismiss the case. On November 9, 1987, the U.S. District Court for the District of New Jersey (Judge Maryanne Trump Barry) declined to issue summary judgment, holding that the plaintiff had a constitutional right to protection from overcrowding and inadequate classification. The court also held that the prison officials were not entitled to qualified immunity. Ryan v. Burlington County, 674 F.Supp. 464 (D.N.J. 1987). The defendants appealed. On November 2, 1988, the U.S. Court of Appeals for the Third Circuit (Judge William D. Hutchinson) affirmed the district court's ruling. Ryan v. Burlington County, 860 F.2d 1199 (3rd Cir. 1988). The defendants appealed. On April 17, 1989, the U.S. Supreme Court denied the petition for writ of certiorari. Fauver v. Ryan, 490 U.S. 1020 (1989).

The corrections officers and members of the County Board of Chosen Freeholders who were defendants in the case also asked the district court to grant them qualified immunity. On March 6, 1989, the district court (Judge Barry) held that the corrections officers were entitled to qualified immunity, but that the members of the county board, which had assumed control of the jail, were not. Ryan v. Burlington County, 708 F.Supp. 623 (D.N.J. 1989). The county board appealed. On November 21, 1989, the Third Circuit affirmed the district court's decision. Ryan v. Burlington County, 889 F.2d 1286 (3rd Cir. 1989). We have no further information on the proceedings in this case.

Kristen Sagar - 10/13/2006


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Defendant-type
Jurisdiction-wide
General
Assault/abuse by residents/inmates/students
Classification / placement
Personal injury
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Burlington County Jail
Plaintiff Description Detainee rendered quadriplegic by cellmate
Indexed Lawyer Organizations None on record
Class action status sought Unknown
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Unknown
Source of Relief Settlement
Form of Settlement None on record
Order Duration 1981 - n/a
Case Closing Year n/a
Case Ongoing No
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
No docket sheet currently in the collection
General Documents
Opinion 11/09/1987 (674 F.Supp. 464) (D.N.J.)
JC-NJ-0005-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion of the Court 11/02/1988 (860 F.2d 1199)
JC-NJ-0005-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 03/06/1989 (708 F.Supp. 623) (D.N.J.)
JC-NJ-0005-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 04/17/1989 (490 U.S. 1020)
JC-NJ-0005-0005.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Opinion of the Court 11/21/1989 (889 F.2d 1286)
JC-NJ-0005-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Barry, Maryanne Trump (D.N.J., Third Circuit)
JC-NJ-0005-0001 | JC-NJ-0005-0003
Gawthrop, Robert S. III (E.D. Pa.)
JC-NJ-0005-0004
Greenberg, Morton Ira (Third Circuit)
JC-NJ-0005-0004
Hutchinson, William D. (Third Circuit)
JC-NJ-0005-0002
Mansmann, Carol Los (W.D. Pa., Third Circuit)
JC-NJ-0005-0004
Monitors/Masters None on record
Plaintiff's Lawyers Denke, Kurt (New Jersey)
JC-NJ-0005-0003 | JC-NJ-0005-0004
Dragon, Albert (Pennsylvania)
JC-NJ-0005-0002
Goldberg, Joseph (New Jersey)
JC-NJ-0005-0001 | JC-NJ-0005-0002 | JC-NJ-0005-0003 | JC-NJ-0005-0004
Defendant's Lawyers Derry, Douglass L. (New Jersey)
JC-NJ-0005-0001 | JC-NJ-0005-0002
Edwards, W. Cary (New Jersey)
JC-NJ-0005-0001 | JC-NJ-0005-0002
Knox, Stephen R. (New Jersey)
JC-NJ-0005-0001
McDonnell, John F. (New Jersey)
JC-NJ-0005-0004
Schafer, Jeffrey D. (New Jersey)
JC-NJ-0005-0003
Tosti, Robert M. (New Jersey)
JC-NJ-0005-0003 | JC-NJ-0005-0004
Other Lawyers None on record

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