Filed Date: April 20, 1977
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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)
Barry, Maryanne Trump (New Jersey)
Denke, Kurt (New Jersey)
Dragon, Albert (Pennsylvania)
Ciancia, James J. (New Jersey)
Derry, Douglass L. (New Jersey)
Barry, Maryanne Trump (New Jersey)
Gawthrop, Robert S. III (Pennsylvania)
Greenberg, Morton Ira (New Jersey)
Hutchinson, William D. (Pennsylvania)
Mansmann, Carol Los (Pennsylvania)
Last updated Feb. 15, 2024, 3:02 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: New Jersey
Case Type(s):
Key Dates
Filing Date: April 20, 1977
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Detainee rendered quadriplegic by cellmate
Plaintiff Type(s):
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):
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Substantive Due Process
Unreasonable search and seizure
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Source of Relief:
Order Duration: 1981 - None
Issues
General:
Jails, Prisons, Detention Centers, and Other Institutions:
Assault/abuse by staff (facilities)
Type of Facility: