University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Bryant v. Coughlin PC-NY-0015
Docket / Court 94-2940 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Prison Conditions
Case Summary
Julius Bryant filed a pro-se lawsuit in the U.S. District Court for the Southern District of New York against the New York Department of Corrections on April 22, 1994, seeking damages for deliberate indifference to his medical needs for his disabling back condition while he was an inmate at Green ... read more >
Julius Bryant filed a pro-se lawsuit in the U.S. District Court for the Southern District of New York against the New York Department of Corrections on April 22, 1994, seeking damages for deliberate indifference to his medical needs for his disabling back condition while he was an inmate at Green Haven Correctional Facility ("Green Haven"). Following a jury trial, the action was settled on February 20, 1998, by an agreement which called for plaintiff's admission to the Unit for the Physically Disabled ("UPD") at Green Haven and his entitlement to the "benefits of treatment at the UPD in accordance with the rules and regulations of the prison and the statement of the Department of Corrections." The agreement contained a clause recognizing the parties' right to bring to the court's attention any violation of the agreement, and the court's power to issue any order necessary to ensure the agreement is followed.

The plaintiff later filed a motion for contempt against the Department of Corrections, alleging violation of the settlement agreement; Defendants moved to terminate the agreement, alleging it was a violation of the Prisoner Litigation Reform Act.

On April 21, 1999, the U.S. District Court for the Southern District of New York (Judge Thomas P. Griesa) denied plaintiff's motion on grounds that contempt is an inappropriate remedy when the settlement agreement is not a court order or decree. Bryant v. Coughlin, No. 94-2940, 1999 WL 232705 (S.D.N.Y. Apr. 21, 1999).

Judge Griesa also denied defendants' motion to terminate the agreement. Defendants had asserted that the agreement was properly construed as a consent decree, and as such, that it violated the terms of the PLRA, which prohibits the court from issuing prospective relief. Judge Greisa found that the agreement was a private settlement agreement but that it was still inconsistent with the PLRA. However, Judge Griesa refused to terminate the agreement, which had been in effect for more than a year. Rather, he held that the proper remedy was to amend the offending clause of the agreement.

Plaintiff later claimed that defendants violated the agreement when they moved him from the UPD to Shawangunk Correctional Facility. On October 29, 1999, Judge Griesa rejected plaintiff's motion, finding that nothing in the agreement prevented prison authorities from moving plaintiff to protect his safety. Bryant v. Coughlin, No. 94-2940, 1999 WL 983865 (S.D.N.Y. Oct. 29, 1999). This ruling was affirmed in an unpublished opinion by the Second Circuit Court of Appeals on March 9, 2001. Bryant v. Coughlin, 5 Fed. Appx. 45, No. 00-0020, 2001 WL 246042 (2d. Cir. Mar. 9, 2001).

Megan Raynor - 01/23/2006


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Issues and Causes of Action
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Issues
Medical/Mental Health
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. ยง 1983
Defendant(s) New York Department of Corrections
Plaintiff Description Inmate incarcerated in Green Haven seeking damages for deliberate indifference to his medical needs
Indexed Lawyer Organizations None on record
Class action status sought Unknown
Class action status granted Unknown
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1998 - n/a
Case Closing Year n/a
Case Ongoing Unknown
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)
94-2940 (S.D.N.Y.) 06/08/2001
PC-NY-0015-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Opinion 04/21/1999 (1999 WL 232705 / 1999 U.S.Dist.LEXIS 5669) (S.D.N.Y.)
PC-NY-0015-0002 PDF | WESTLAW| LEXIS | Detail
Opinion 10/29/1999 (1999 WL 983865) (S.D.N.Y.)
PC-NY-0015-0003 PDF | WESTLAW | Detail
Summary Order 03/09/2001 (5 Fed.Appx. 45)
PC-NY-0015-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Griesa, Thomas Poole (S.D.N.Y.)
PC-NY-0015-0002 | PC-NY-0015-0003 | PC-NY-0015-9000
Leval, Pierre Nelson (Second Circuit, S.D.N.Y.)
PC-NY-0015-0001
Newman, Jon Ormond (Second Circuit, D. Conn.)
PC-NY-0015-0001
Peck, Andrew Jay (S.D.N.Y.) [Magistrate]
PC-NY-0015-9000
Sack, Robert David (Second Circuit)
PC-NY-0015-0001
Monitors/Masters None on record
Plaintiff's Lawyers Weinstein, Carol (New York)
PC-NY-0015-9000
Defendant's Lawyers Spitzer, Eliot (New York)
PC-NY-0015-0001
Weinstein, Jay T. (New York)
PC-NY-0015-9000
Other Lawyers None on record

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