University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Vazquez v. Gray JC-NY-0008
Docket / Court 78 CIV. 4914 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Jail Conditions
Case Summary
In 1979, inmates at the Westchester County Jail filed a class action lawsuit in the U.S. District Court for the Southern District of New York against the Westchester County Department of Corrections under 42 U.S.C. §1983. The plaintiffs claimed that conditions of overcrowding at the jail violated ... read more >
In 1979, inmates at the Westchester County Jail filed a class action lawsuit in the U.S. District Court for the Southern District of New York against the Westchester County Department of Corrections under 42 U.S.C. §1983. The plaintiffs claimed that conditions of overcrowding at the jail violated constitutional guidelines and placed a strain on all of the facilities, including medical, food service, law library, and recreation. The plaintiffs sought preliminary injunction concerning these conditions.

On September 28, 1981, the court inspected the conditions at WCJ, which housed pretrial detainees. The court (Judge Gerard Louis Goettel) found that the overcrowded conditions violated constitutional guidelines and that the jail limited the inmates' access to recreation areas and other privileges. Vazquez v. Gray, 523 F.Supp. 1359 (S.D.N.Y. 1981). The court noted and defendants conceded that the strained conditions had contributed to riots at the jail in July of 1981. However, the court refused to impose a population limit on the jail and instead issued the following remedies on October 16, 1981:

1.      Prohibited the use of floor mattresses as constitutionally impermissible.

2.      Prohibited the housing of more than two minors in a single cell.

3.      Prohibited housing prisoners in dayrooms for longer than five days.

4.      Limited the use of dormitories to their present and planned uses, finding that the conditions within the dormitories did not amount to a deprivation.

Information regarding the jail's compliance with these remedies is unknown. In 2010, Davis v. Gusman, No. CIVA 09-7195, 2010 WL 1727825 (E.D. La. Apr. 13, 2010) refused to follow the ruling of this case.

Angela Heverling - 02/06/2006
Richard Jolly - 11/04/2014


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Equal Protection
Content of Injunction
Preliminary relief granted
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Food service / nutrition / hydration
Library (non-law) access
Sanitation / living conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Westchester County Jail
Plaintiff Description inmates at the Westchester County Department of Corrections
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1981 - n/a
Case Closing Year n/a
Case Ongoing Unknown
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 10/16/1981 (523 F.Supp. 1359) (S.D.N.Y.)
JC-NY-0008-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Goettel, Gerard Louis (S.D.N.Y.) [Magistrate]
JC-NY-0008-0001
Monitors/Masters None on record
Plaintiff's Lawyers Angelos, Claudia (New York)
JC-NY-0008-0001
Berger, Joel (New York)
JC-NY-0008-0001
Greenberg, Jack (New York)
JC-NY-0008-0001
Winter, Steven L. (New York)
JC-NY-0008-0001
Defendant's Lawyers Slaaten, Marilyn J. (New York)
JC-NY-0008-0001 | JC-NY-0008-0001
Yasgur, Samuel S. (New York)
JC-NY-0008-0001 | JC-NY-0008-0001
Other Lawyers None on record

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