University of Michigan Law School
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Case Name Albro v. County of Onondaga JC-NY-0014
Docket / Court 85-1425 ( N.D.N.Y. )
State/Territory New York
Case Type(s) Jail Conditions
Case Summary
On October 25, 1985, pretrial detainees and inmates in the Onondaga County Jail in New York filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Northern District of New York against both the county and the state seeking declaratory and injunctive relief to ... read more >
On October 25, 1985, pretrial detainees and inmates in the Onondaga County Jail in New York filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Northern District of New York against both the county and the state seeking declaratory and injunctive relief to reduce the jail population to levels that would insure the inmates were not being held in unconstitutional conditions. The inmates were represented by Syracuse University Law Clinic. On November 22, 1985, the court (Judge Howard Munson) certified the class including both pretrial detainees and convicted inmates. On February 3, 1986, after a hearing on the inmate's motion for a preliminary injunction, the court (Judge Munson) granted the preliminary injunction, enjoining the defendants from housing inmates on the floor, housing general inmates with mentally ill inmates, and ordered the defendants to prepare a report detailing the number or inmates accepted each day and the charges against them. Albro v. Co. of Onondaga, New York, 627 F.Supp. 1280 (N.D.N.Y. 1986). The court suggested, but did not require, that the county stop accepting discretionary inmates. Soon after, the county terminated its contracts with other entities to house their inmates. On July 17, 1986, the court appointed a special master (Donald Stoughton). On June 26, 1987, the court ordered the state to reduce the number of state-ready inmates and ordered the county not to allow the jail population to exceed 248. On January 14, 1988 the court (Judge Munson) ordered a permanent injunction against the defendants.

On April 5, 1988, the court (Judge Munson) found that the majority of people being held at the jail were pretrial detainees and therefore the Fourteenth Amendment Due Process Clause governed their confinement. Albro v. Onondaga County, N.Y., 681 F.Supp. 991 (N.D.N.Y. 1988). The court found that the conditions at the jail were unconstitutional and ordered that a population cap of 212 inmates be established and that the county submit a short term plan to remedy the constitutional violations. The court also ordered that only minimum security inmates be housed in the gymnasium (maximum 15 inmates) and imposed fines of $1,000 per day for each prisoner in excess of the population cap. On May 10, 1988, on recommendation from the special master, the court (Judge Munson) raised the population cap for the gymnasium from 15 to 24 inmates. Albro v. Co. of Onondaga, New York, no. 85-CV-1425, 1988 WL 46616 (N.D.N.Y. May 10, 1988).

Litigation continued until the parties reached a settlement agreement and on March 3, 1997, the court (Judge Munson) approved the agreement, dismissed the case, and remitted the fines accrued against the defendants upon their implementation of the programs agreed to. The court stated that prior orders and judgments were decreed to be satisfied.

The plaintiffs filed a motion for attorney's fees and on February 4, 1998, the court (Judge Munson) found that the plaintiffs were prevailing parties and granted the motion.

Jaclyn Adams - 04/05/2006


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Pre-PLRA Population Cap
General
Totality of conditions
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Onondaga Country
Plaintiff Description pretrial detainees and inmates in the Onondaga County Jail in New York
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1986 - 1997
Case Closing Year 1997
Case Ongoing No
Additional Resources
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  Bravo v. Board of Commissioners of Dona Ana County
http://www.bazelon.org/
Date: 2017
By: The Bazelon Center (The Bazelon Center)
[ Detail ] [ External Link ]

Docket(s)
85-1425 (N.D.N.Y.)
JC-NY-0014-9000.pdf | Detail
Date: 02/04/1998
Source: PACER [Public Access to Court Electronic Records]
General Documents
Memorandum-Decision and Order (627 F.Supp. 1280) (N.D.N.Y.)
JC-NY-0014-0001.pdf | WESTLAW| LEXIS | Detail
Date: 02/03/1986
Source: Google Scholar
Memorandum-Decision and Order (681 F.Supp. 991) (N.D.N.Y.)
JC-NY-0014-0002.pdf | WESTLAW| LEXIS | Detail
Date: 04/05/1988
Source: Google Scholar
Order (1998 WL 46616 / 1998 U.S.Dist.LEXIS 4054) (N.D.N.Y.)
JC-NY-0014-0004.pdf | WESTLAW| LEXIS | Detail
Date: 05/10/1988
Memorandum-Decision and Order (1998 WL 52013 / 1998 U.S.Dist.LEXIS 1444) (N.D.N.Y.)
JC-NY-0014-0003.pdf | WESTLAW| LEXIS | Detail
Date: 02/04/1998
Judges Munson, Howard G. (N.D.N.Y.)
JC-NY-0014-0001 | JC-NY-0014-0002 | JC-NY-0014-0003 | JC-NY-0014-0004 | JC-NY-0014-9000
Plaintiff's Lawyers Blood, Deborah J. (New York)
JC-NY-0014-0001
Braveman, Daan (New York)
JC-NY-0014-0001
Cox, Kerri L. (New York)
JC-NY-0014-9000
Dembs, Marcy Robinson (New York)
JC-NY-0014-0001
Greenspan, David (New York)
JC-NY-0014-0001
Hazen, Kirk S. (New York)
JC-NY-0014-0002 | JC-NY-0014-0004 | JC-NY-0014-9000
Hoft, Janine L. (New York)
JC-NY-0014-0003 | JC-NY-0014-9000
Jenkins, Jonathan M. (New York)
JC-NY-0014-9000
O'Brien, Connor (New York)
JC-NY-0014-0001
Waight, Brenda (New York)
JC-NY-0014-0001
Defendant's Lawyers Abrams, Robert W. (New York)
JC-NY-0014-0001 | JC-NY-0014-0002 | JC-NY-0014-0004
Gerber, Jon A. (New York)
JC-NY-0014-0003 | JC-NY-0014-0004
Mulroy, John H. (New York)
JC-NY-0014-0003
Rossi, Robert J. (New York)
JC-NY-0014-0001 | JC-NY-0014-0002
Silver, Paul D. (New York)
JC-NY-0014-0001 | JC-NY-0014-9000
Tucker, Diane E. (New York)
JC-NY-0014-0001 | JC-NY-0014-0002 | JC-NY-0014-0004 | JC-NY-0014-9000
Williams, Lawrence R. (New York)
JC-NY-0014-0003 | JC-NY-0014-9000
Zimmerman, Lawrence (New York)
JC-NY-0014-0002 | JC-NY-0014-0004

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