Case: Vespa v. Board of Freeholders of Burlington County

3:77-00765 | U.S. District Court for the District of New Jersey

Filed Date: April 20, 1977

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Case Summary

On April 20, 1977, inmates at the Burlington County Jail in Mount Holly, New Jersey, filed lawsuits under 42 U.S.C. §1983 against the county in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by overcrowding and inadequate classification procedures at the jail. The case was eventually consolidated with another case, Morrison v. Brennan, Civ. No. 78-0628, (D…

On April 20, 1977, inmates at the Burlington County Jail in Mount Holly, New Jersey, filed lawsuits under 42 U.S.C. §1983 against the county in the U.S. District Court for the District of New Jersey. The plaintiffs asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by overcrowding and inadequate classification procedures at the jail.

The case was eventually consolidated with another case, Morrison v. Brennan, Civ. No. 78-0628, (D.N.J. March 28, 1978). On June 1, 1981, the U.S. District Court for the District of New Jersey (Judge Dickinson R. Debevoise) approved a settlement agreement in the case, providing for population caps, better classification procedures, and renovation of the jail.

Two and a half years later, an inmate named Maurice Scott was being held in an overcrowded cell in violation of the settlement agreement, awaiting his long overdue transfer to state prison. Scott, an inmate known for his violent attacks on other inmates, shared his cell with Timothy Ryan, a pretrial detainee being held for an alleged traffic violation. On October 4, 1983, Scott attacked Ryan, breaking his neck and rendering Ryan a quadriplegic.

In April 1985, Ryan filed a lawsuit under 42 U.S.C. §§ 1983, 1985, and 1988, as well as various state laws, against the New Jersey Department of Corrections and Burlington County in the U.S. District Court for the District of New Jersey. Ryan asked the court for compensatory and punitive damages, alleging that his constitutional rights had been violated by overcrowding, inadequate classification procedures, and failure to protect him from a known violent inmate.

The defendants asked the court to issue summary judgment in their favor and dismiss the case. On November 9, 1987, the U.S. District Court for the District of New Jersey (Judge Maryanne Trump Barry) declined to issue summary judgment, holding that the plaintiff had a constitutional right to protection from overcrowding and inadequate classification. The court also held that the prison officials were not entitled to qualified immunity. Ryan v. Burlington County, 674 F.Supp. 464 (D.N.J. 1987). The defendants appealed. On November 2, 1988, the U.S. Court of Appeals for the Third Circuit (Judge William D. Hutchinson) affirmed the district court's ruling. Ryan v. Burlington County, 860 F.2d 1199 (3rd Cir. 1988). The defendants appealed. On April 17, 1989, the U.S. Supreme Court denied the petition for writ of certiorari. Fauver v. Ryan, 490 U.S. 1020 (1989).

The corrections officers and members of the County Board of Chosen Freeholders who were defendants in the case also asked the district court to grant them qualified immunity. On March 6, 1989, the district court (Judge Barry) held that the corrections officers were entitled to qualified immunity, but that the members of the county board, which had assumed control of the jail, were not. Ryan v. Burlington County, 708 F.Supp. 623 (D.N.J. 1989). The county board appealed. On November 21, 1989, the Third Circuit affirmed the district court's decision. Ryan v. Burlington County, 889 F.2d 1286 (3rd Cir. 1989). We have no further information on the proceedings in this case.

Summary Authors

Kristen Sagar (10/13/2006)

People


Judge(s)

Barry, Maryanne Trump (New Jersey)

Attorney for Plaintiff

Denke, Kurt (New Jersey)

Dragon, Albert (Pennsylvania)

Attorney for Defendant

Ciancia, James J. (New Jersey)

Derry, Douglass L. (New Jersey)

Judge(s)

Barry, Maryanne Trump (New Jersey)

Gawthrop, Robert S. III (Pennsylvania)

Greenberg, Morton Ira (New Jersey)

Hutchinson, William D. (Pennsylvania)

Mansmann, Carol Los (Pennsylvania)

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Documents in the Clearinghouse

Document

2:85-02002

Opinion

Ryan v. Burlington County

Nov. 9, 1987

Nov. 9, 1987

Order/Opinion

87-05847

Opinion of the Court

Ryan v. Burlington County

U. S. Court of Appeals for the Third Circuit

Nov. 2, 1988

Nov. 2, 1988

Order/Opinion

2:85-02002

Opinion

Ryan v. Burlington County

March 6, 1989

March 6, 1989

Order/Opinion

88-01365

Opinion

Fauver v. Ryan

Supreme Court of the United States

April 17, 1989

April 17, 1989

Order/Opinion

89-05286

Opinion of the Court

Ryan v. Burlington County

U. S. Court of Appeals for the Third Circuit

Nov. 21, 1989

Nov. 21, 1989

Order/Opinion

Docket

Last updated Feb. 15, 2024, 3:02 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: New Jersey

Case Type(s):

Jail Conditions

Key Dates

Filing Date: April 20, 1977

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Detainee rendered quadriplegic by cellmate

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: Unknown

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Burlington County Jail (Burlington), County

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Due Process: Substantive Due Process

Unreasonable search and seizure

Available Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Unknown

Source of Relief:

Settlement

Order Duration: 1981 - None

Issues

General:

Classification / placement

Personal injury

Jails, Prisons, Detention Centers, and Other Institutions:

Crowding / caseload

Assault/abuse by staff (facilities)

Type of Facility:

Government-run