University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Valentine v. Beyer PC-NJ-0010
Docket / Court 85-4401 ( D.N.J. )
State/Territory New Jersey
Case Type(s) Prison Conditions
Case Summary
In 1987, inmates at the Trenton State Prison in New Jersey filed a pro se lawsuit under 42 U.S.C. §1983 against the New Jersey Department of Corrections in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for injunctive relief, alleging that the prison's ... read more >
In 1987, inmates at the Trenton State Prison in New Jersey filed a pro se lawsuit under 42 U.S.C. §1983 against the New Jersey Department of Corrections in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for injunctive relief, alleging that the prison's legal assistance program was inadequate and denied them access to the courts.

The district court (Judge Robert E. Cowen) granted injunctive relief to the plaintiffs, and the defendants appealed. On June 20, 1988, the U.S. Court of Appeals for the Third Circuit (Judge Carol Los Mansmann) affirmed the district court's decision. Valentine v. Beyer, 850 F.2d 951 (3rd Cir. 1988). On October 4, 2006, the Executive Director of the Inmate Legal Association moved, on behalf of the certified class, to enforce and modify judgments and settlement agreement and to hold defendants in contempt of court, and requested money damages. On April 8, 2008, the court ruled that the action to enforce the settlement agreement was a separate contract dispute, and the proper forum to enforce it was in New Jersey state court, absent an independent basis for federal jurisdiction. The court also stated that likely the proper vehicle to enforce the settlement agreement would be to file a separate action, as opposed to a motion in this closed case.

On October 20,2009 the Inmate Legal Association did file in state court and you can find an appellate opinion on the case here.

Kristen Sagar - 02/16/2007
Abigail DeHart - 11/05/2016


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Issues and Causes of Action
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Issues
General
Access to lawyers or judicial system
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Trenton State Prison
Plaintiff Description Inmates challenging adequacy of prison's legal assistance program
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement None on record
Order Duration 1988 - n/a
Case Closing Year 1994
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
85-4401 (D.N.J.) 01/20/1998
PC-NJ-0010-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
85-cv-04401 (D.N.J.) 04/08/2008
PC-NJ-0010-9001.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Opinion 06/20/1988 (850 F.2d 951)
PC-NJ-0010-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Notice of Motion to Enforce and Modify Judgments and Settlement Agreement, and Hold Defendants in Contempt of Court 09/27/2006
PC-NJ-0010-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion 04/08/2008 (D.N.J.)
PC-NJ-0010-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Cooper, Mary Little (D.N.J.)
PC-NJ-0010-0003 | PC-NJ-0010-9001
Mansmann, Carol Los (W.D. Pa., Third Circuit)
PC-NJ-0010-0001
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers Campbell, Sarah Brie (New Jersey)
PC-NJ-0010-9001
Kahn, Michael E. (New Jersey)
PC-NJ-0010-0001 | PC-NJ-0010-9000
Long, Janine L. (New Jersey)
PC-NJ-0010-9001
Other Lawyers None on record

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