Case: Valentine v. Englehardt

2:78-cv-00270 | U.S. District Court for the District of New Jersey

Filed Date: Feb. 8, 1978

Closed Date: July 21, 1980

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Case Summary

In February 1978, seven pre-trial detainees at the Passaic County Jail in New Jersey filed a class action lawsuit under 42 U.S.C. § 1983 against representatives of the county in the U.S. District Court for the District of New Jersey. The plaintiffs, represented by the Office of Inmate Advocacy at the New Jersey Department of the Public Advocate, asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by numerous conditions at the jail.…

In February 1978, seven pre-trial detainees at the Passaic County Jail in New Jersey filed a class action lawsuit under 42 U.S.C. § 1983 against representatives of the county in the U.S. District Court for the District of New Jersey. The plaintiffs, represented by the Office of Inmate Advocacy at the New Jersey Department of the Public Advocate, asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by numerous conditions at the jail. On April 28, 1978, the Court certified a class consisting of all current and future inmates at the Passaic County Jail.

On May 31, 1978, the inmates filed an amended complaint, dividing their allegations into ten categories, including complaints of overcrowding, inadequate classification, unsanitary conditions, inadequate medical care, food, disciplinary procedures or exercise, and undue policies concerning telephone use, visitation and access to the courts. The complaint also alleged sex discrimination, complaining that women were not allowed to attend religious services at the chapel, and had far more limited access to the gym and sick call. They also complained of denial of newspapers and magazines. The complaint further alleged that the jail was racially segregated and that violent inmates were housed with non-violent ones, that inmates slept on dirty, vermin-infested mattresses, and that living spaced lacked proper heat, hot water or ventilation, and that toilets were located near and in view of other inmates and inmate eating areas.

In February 1979, the parties reported they had reached settlement on all but two issues: visiting practices and access to newspapers. On March 6, 1979, the parties settled the claim concerning inmate access to reading materials. The court approved the Stipulation of Agreement and Consent Order on April 10, 1979.

The Consent Order noted that many improvements had been made to the jail during the litigation, and also provided that defendants ensure the cleanliness of inmate living areas and food, that women be given equal access to all facilities and services, that disciplinary procedures be improved, and that inmates have access to law books, attorneys and toilet areas screened from outside viewing.

The only issue remaining for litigation concerned the Jail's visitation policies. On July 18, 1979, the U.S. District Court for the District of New Jersey (Judge Herbert Jay Stern) held that the county jail procedures totally barring visitation by inmates' children were unconstitutional. Valentine v. Englehardt, 474 F.Supp. 294 (D.N.J 1979). The defendants asked the court for reconsideration, and on July 21, 1980, the court further held that the jail's ban on contact visits was constitutional because it banned such visits for security purposes rather than for purposes of punishment, and that consideration outweighed the benefits of such visitation to inmates. Valentine v. Englehardt, 492 F.Supp. 1039 (D.N.J. 1980). We have no further information on the proceedings in this case.

Summary Authors

Kristen Sagar (10/7/2006)

People


Judge(s)

Stern, Herbert Jay (New Jersey)

Attorney for Plaintiff

Mintz, Jeffry A. (New Jersey)

Attorney for Defendant

Convery, James V. (New Jersey)

Kopf, Randy R. (New Jersey)

Verp, Martin (New Jersey)

Judge(s)

Stern, Herbert Jay (New Jersey)

Attorney for Plaintiff

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Documents in the Clearinghouse

Document

2:78-cv-00270

Opinion

July 18, 1979

July 18, 1979

Order/Opinion

474 F.Supp. 474

2:78-cv-00270

Opinion

July 21, 1980

July 21, 1980

Order/Opinion

492 F.Supp. 492

Docket

Last updated March 25, 2024, 3:05 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: New Jersey

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Feb. 8, 1978

Closing Date: July 21, 1980

Case Ongoing: No

Plaintiffs

Plaintiff Description:

all current and future inmates at the Passaic County Jail in New Jersey

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Passaic County Jail (Passaic), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Due Process: Procedural Due Process

Free Exercise Clause

Freedom of speech/association

Cruel and Unusual Punishment

Available Documents:

Any published opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1979 - None

Issues

General:

Access to lawyers or judicial system

Bathing and hygiene

Classification / placement

Disciplinary procedures

Food service / nutrition / hydration

Mail

Parents (visitation, involvement)

Racial segregation

Recreation / Exercise

Religious programs / policies

Siblings (visitation, placement)

Staff (number, training, qualifications, wages)

Totality of conditions

Jails, Prisons, Detention Centers, and Other Institutions:

Law library access

Visiting

Crowding / caseload

Discrimination-basis:

Sex discrimination

Affected Sex or Gender:

Female

Male

Medical/Mental Health:

Medical care, general

Type of Facility:

Government-run