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Civil Rights Litigation Clearinghouse
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Case Name Reynolds v. Arnone PC-CT-0020
Docket / Court 3:13-cv-01465-SRU ( D. Conn. )
State/Territory Connecticut
Case Type(s) Prison Conditions
Special Collection Solitary confinement
Case Summary
On October 4, 2013, a death row inmate at the Connecticut Northern Correctional Institution (NCI) filed this lawsuit pro se in the U.S. District Court for the District of Connecticut. The plaintiff sued the commissioner of the Connecticut Department of Corrections and six other state officials in ... read more >
On October 4, 2013, a death row inmate at the Connecticut Northern Correctional Institution (NCI) filed this lawsuit pro se in the U.S. District Court for the District of Connecticut. The plaintiff sued the commissioner of the Connecticut Department of Corrections and six other state officials in their official and individual capacities under 42 USC § 1983 and the ADA. The plaintiff sought declaratory and injunctive relief, including a release from 23 hour-per-day solitary confinement, an end to universal use of restraints while outside of his cell, access to group religious services, visitation rights, a return of private property, and mental health care. The plaintiff also sought compensation and damages. Specifically, the plaintiff claimed that the defendants violated his Fifth, Eighth, and Fourteenth Amendment rights, Article I Section 10 Ex Post Facto and Bill of Attainder clauses, and the 1949 Geneva Convention prohibition on collective punishment (this last charge and Fifth Amendment claims were dropped after he received legal representation).

The plaintiff had originally been sentenced to death and served 21 years on death row. After the state abolished capital punishment in 2015, he was re-sentenced to life in prison without the possibility of parole in 2017 (during this litigation). Throughout the 23 years of his sentence prior to the time of filing, the plaintiff lived in a 12x7 foot concrete cell with only a three-inch wide window. He spent between 22 and 23 hours every day in this cell. He had extremely limited contact with other prisoners and was handcuffed or shackled whenever he left his cell. He sought injunctive relief to order the state to release him from solitary confinement and place him in the general prison population, to pay back wages, to allow group 7th Day Adventist religious services, to return all personal property, to stop the elevated uses of restraints, to improve mental health care, to provide better access to recreation and dining facilities, to restore his security levels and accompanying privileges to his pre-2017 status, to end collective punishments, and to end discrimination against life-term inmates.

The case was assigned to Judge Stefan R. Underhill. In 2014, the case was referred to Magistrate Judge William I. Garfinkel for settlement conferences.

On March 3, 2015, the defendants moved for summary judgment. The defendants first claimed that they were immune in their official capacities from money damages under the Eleventh Amendment, and second that they were entitled to qualified immunity in their individual capacities. They also argued that the conditions on death row were constitutional and satisfied the Eighth Amendment. But before the court ruled on the motion or the plaintiff even replied, a clinical professor at Columbia University School of Law was appointed as pro bono counsel for the plaintiff. The motion was denied as moot and the plaintiff was given opportunity to amend with new counsel. After multiple extensions were granted, the plaintiff filed an amended complaint on June 30, 2017.

The plaintiff alleged in the amended complaint that state statutes that transferred former death row prisoners to solitary confinement unconstitutionally amounted to a bill of attainder and an ex post facto law. The complaint also dropped claims of fifth amendment and Geneva Convention violations. The plaintiff still sought a permanent injunction, requesting that the defendants submit a plan to the court to release him from solitary confinement, provide mental health care, and end his physical and social isolation, end his sensory deprivation.

After over a year of discovery, the parties filed cross-motion for summary judgment in November 2018. On August 27, 2019, Judge Stefan Underhill granted the plaintiff’s motion and denied the defendants’ motion. Judge Underhill found that the conditions of confinement violated the plaintiff’s Eighth Amendment right to be free from cruel and unusual punishment because they were deliberately indifferent to the serious risks of the plaintiff's confinement. The court also found that the defendants violated the plaintiff's Fourteenth Amendment rights to due process and equal protection. Furthermore, Judge Underhill found that the state's statute on death row was an unconstitutional bill of attainder in violation of Article I Section 10 of the constitution. Judge Underhill granted permanent injunctive relief to the plaintiff.

In a separate injunctive and declaratory relief order, the court ordered the state to end plaintiff’s placement in the high security confinement, to allow the plaintiff to leave his cell for more than four hours per day, and to stop his segregation from other prisoners. The court also ordered that the state provide a “meaningful individualized classification determination“ for plaintiff's security level every six months. The Judge also ordered that the state stop enforcement of the death row "special circumstances" policy against any current or future prisoner. Finally, the court ordered the state to submit a status report to him within 30 days detailing how these orders would be effectuated.

On September 4, 2019, Judge Underhill granted in part the defendants’ motion to stay his order. But the order denied a request to stay the requirement of a 30-day status report.

On September 9, 2019, the defendants appealed Judge Underhill’s order granting summary judgment to the United States Court of Appeals for the Second Circuit (Docket No. 19-2858).

On September 20, the defendants submitted a motion for stay to the District Court pending their appeal to the Circuit Court. On September 25, another prisoner held under the state "special circumstances" statute on death row filed a motion to intervene. The intervenor sought to oppose the stay of the injunction. The defendants also filed the status report that same day. On October 16, the court granted the stay as to determining damages but denied the stay as to enforcing injunctive relief.

The case is pending appeal in the Second Circuit.

Francis O'Rourke - 09/23/2019
Chelsea Rinnig - 01/09/2020


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process: Procedural Due Process
Equal Protection
Ex Post Facto
Content of Injunction
Reporting
Defendant-type
Corrections
Disability
Mental impairment
General
Administrative segregation
Classification / placement
Conditions of confinement
Loss or damage to property
Recreation / Exercise
Religious programs / policies
Restraints : physical
Sanitation / living conditions
Solitary confinement/Supermax (conditions or process)
Torture
Visiting
Medical/Mental Health
Mental health care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Commissioner of Connecticut Dept. of Corrections
Plaintiff Description Individual prisoner in solitary confinement.
Class action status sought No
Class action status granted No
Filed Pro Se Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Declaratory Judgment
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Order Duration 2019 - n/a
Filing Year 2013
Case Ongoing Yes
Additional Resources
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  Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
Date: May 2006
By: Margo Schlanger (Washington University Faculty)
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
Book
Date: Jan. 1, 1998
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
3:13-cv-01465 (D. Conn.)
PC-CT-0020-9000.pdf | Detail
Date: 09/20/2019
Source: PACER [Public Access to Court Electronic Records]
General Documents
Pro Se Prisoner Civil Rights Complaint [ECF# 1]
PC-CT-0020-0001.pdf | Detail
Date: 10/04/2013
Source: PACER [Public Access to Court Electronic Records]
Second Amended Complaint [ECF# 72]
PC-CT-0020-0002.pdf | Detail
Date: 06/30/2017
Source: PACER [Public Access to Court Electronic Records]
Memorandum of Decision [ECF# 155] (2019 WL 4039015) (D. Conn.)
PC-CT-0020-0003.pdf | WESTLAW | Detail
Date: 08/27/2019
Source: PACER [Public Access to Court Electronic Records]
Permanent Injunction Order [ECF# 156] (D. Conn.)
PC-CT-0020-0004.pdf | Detail
Date: 08/27/2019
Source: PACER [Public Access to Court Electronic Records]
Ruling on Defendants' Motion for Immediate Stay [ECF# 159] (D. Conn.)
PC-CT-0020-0005.pdf | Detail
Date: 09/04/2019
Source: PACER [Public Access to Court Electronic Records]
Defendants' Status Report [ECF# 165]
PC-CT-0020-0006.pdf | Detail
Date: 09/25/2019
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Garfinkel, William I. (D. Conn.) show/hide docs
PC-CT-0020-9000
Underhill, Stefan R. (D. Conn.) show/hide docs
PC-CT-0020-0003 | PC-CT-0020-0004 | PC-CT-0020-0005 | PC-CT-0020-9000
Plaintiff's Lawyers Dignam, Brett (Connecticut) show/hide docs
PC-CT-0020-0002 | PC-CT-0020-9000
Defendant's Lawyers Martone, Michael A (Connecticut) show/hide docs
PC-CT-0020-9000
Melchionne, Madeline A (Connecticut) show/hide docs
PC-CT-0020-0006 | PC-CT-0020-9000
Strom, Steven R. (Connecticut) show/hide docs
PC-CT-0020-0006 | PC-CT-0020-9000

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