University of Michigan Law School
Civil Rights Litigation Clearinghouse
new search
page permalink
Case Name Connecticut v. Northern Correctional Institution PC-CT-0015
Docket / Court 3:03-cv-01352-RNC ( D. Conn. )
State/Territory Connecticut
Case Type(s) Prison Conditions
Special Collection Solitary confinement
Attorney Organization ACLU Chapters (any)
ACLU National Prison Project
Case Summary
On August 6, 2003, the State of Connecticut Office of Protection and Advocacy for Persons with Disabilities (OPA) filed a § 1983 lawsuit in the U.S. District Court of Connecticut against the Connecticut Department of Corrections and two prisons it operated. Represented by a coalition of attorneys ... read more >
On August 6, 2003, the State of Connecticut Office of Protection and Advocacy for Persons with Disabilities (OPA) filed a § 1983 lawsuit in the U.S. District Court of Connecticut against the Connecticut Department of Corrections and two prisons it operated. Represented by a coalition of attorneys from the local ACLU, ACLU's National Prison Project, local legal aid organizations, the plaintiffs alleged that prisoners and detainees with mental illness who were confined at CDC's Northern Correctional Institution and Garner Correctional Institution were subjected to unconstitutional conditions of confinement in violation of the Eighth Amendment. According to the complaint, the facilities housed both prisoners and pretrial detainees and subjected individuals with mental illness to conditions that exacerbated their mental illnesses. The plaintiffs detailed the isolation and lack of access to exercise or light, as well as prevalence of use-of-force and restraints. The plaintiffs sought declaratory and injunctive relief to bar defendants from subjecting prisoners with mental illness to these unconstitutional conditions.

Soon after the filing of the lawsuit, the parties entered into settlement negotiations and participated in many court ordered settlement conferences. The parties reached a tentative settlement agreement in March 2004. Approval of the proposed agreement was debated by the Connecticut Legislature and a public hearing was held by the joint Judicial Committee of the Connecticut State Senate and House. The settlement was ratified and the parties filed a joint motion to dismiss and approve the settlement with the District Court on September 22, 2005. The District Court (Judge Robert N. Chatigny) entered an order of dismissal and approved and adopted the terms of the Settlement Agreement on September 26, 2005. The District Court retained jurisdiction to enforce compliance with the Settlement Agreement for three years.

The Agreement provided that services for seriously mentally ill prisoners would be consolidated at the Garner Correctional Institution in Newtown, Connecticut, which would be designed as the mental health institution for the CDC. In order to initially determine which prisoners would be transferred to Garner, an evaluation of the entire prison population at Northern would be conducted by the UConn Health Center Psychiatric staff. The Agreement also called for increased staffing and changes to mental health evaluation and services. All prisoners and detainees held in the most restrictive form of confinement at NCI were assessed by psychiatric experts to determine whether their placement was appropriate. Individuals with serious mental illness or who were at risk of developing serious mental illness were transferred to a facility with intensive psychiatric services. The parties each designated a mental health consultant and a confinement consultant to monitor and evaluate compliance.

The parties subsequently submitted the issue to the court whether the four monitoring consultants would be granted access to prisoners' mental health records. On March 30, 2007, the court granted in part and denied in part the plaintiffs' request. The issue was that while the plaintiffs required access to prisoners' medical records in order to monitor compliance, the defendants were concerned that disclosure without prisoners' consent would violate their constitutional rights. The court applied a balancing test and concluded that the state's interest in disclosure outweighed the burden on the constitutional right, especially because OPA was a state agency designed to protect civil rights. The court denied the motion in part as to certain protected materials, but otherwise granted it and allowed access to the records for the express purpose of monitoring compliance.

On August 5, 2008, the plaintiffs filed a motion for contempt for the defendants' failure to pay expert consultants' reimbursements. The plaintiffs subsequently withdrew the motion by the end of the month after the parties resolved the issue out of court. The defendants made payments to the plaintiff's consultants until December 2008. The court's jurisdiction over the settlement has ended and the case is now closed.

Dan Dalton - 01/31/2007
Chelsea Rinnig - 01/16/2020

compress summary

- click to show/hide ALL -
Issues and Causes of Action
click to show/hide detail
Affected Gender
Constitutional Clause
Cruel and Unusual Punishment
Content of Injunction
Mental impairment
Classification / placement
Restraints : physical
Solitary confinement/Supermax (conditions or process)
Staff (number, training, qualifications, wages)
Suicide prevention
Totality of conditions
Medical/Mental Health
Mental health care, general
Plaintiff Type
State Plaintiff
Type of Facility
Causes of Action 42 U.S.C. § 1983
Defendant(s) Connecticut Department of Corrections
Garner Correctional Institution
Northern Correctional Institution
Plaintiff Description Office of Protection and Advocacy for Persons with Disabilities bringing claims related to the conditions of confinement of prisoners with mental illness
Indexed Lawyer Organizations ACLU Chapters (any)
ACLU National Prison Project
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Attorneys fees
Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 2005 - 2008
Filed 2003
Case Closing Year 2008
Case Ongoing No
Additional Resources
click to show/hide detail
  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
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 ]

3:03-cv-01352-RNC (D. Conn.)
PC-CT-0015-9000.pdf | Detail
Date: 10/03/2008
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
PC-CT-0015-0010.pdf | Detail
Date: 08/06/2003
Settlement Agreement
PC-CT-0015-0001.pdf | Detail
Date: 03/08/2004
Judicial Committee Hearing Transcript for 04/13/2004
PC-CT-0015-0006.pdf | Detail
Date: 04/13/2004
Resolution Approving the Settlement Agreement in State of Connecticut Office of Protection and Advocacy for Persons with Disabilities v. Choinski, et al.
PC-CT-0015-0005.pdf | Detail
Date: 04/21/2004
Order of Dismissal
PC-CT-0015-0003.pdf | Detail
Date: 09/26/2005
Order (D. Conn.)
PC-CT-0015-0002.pdf | Detail
Date: 11/08/2006
Order (D. Conn.)
PC-CT-0015-0004.pdf | Detail
Date: 01/08/2007
Ruling on Plaintiffs' Motion [ECF# 115] (D. Conn.)
PC-CT-0015-0008.pdf | Detail
Date: 03/30/2007
Source: PACER [Public Access to Court Electronic Records]
Motion for Contempt [ECF# 133]
PC-CT-0015-0009.pdf | Detail
Date: 08/05/2008
Source: PACER [Public Access to Court Electronic Records]
Amendment to Paragraph B.9. of the March 8, 2004 Settlement Agreement [ECF# 145]
PC-CT-0015-0007.pdf | Detail
Date: 09/11/2008
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Chatigny, Robert N. (D. Conn.) show/hide docs
PC-CT-0015-0002 | PC-CT-0015-0003 | PC-CT-0015-0004 | PC-CT-0015-9000
Martinez, Donna F. (D. Conn.) [Magistrate] show/hide docs
Plaintiff's Lawyers Alisberg, Nancy B. (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0009 | PC-CT-0015-0010 | PC-CT-0015-9000
Annon, Paulette G. (Connecticut) show/hide docs
Balaban, Eric G. (District of Columbia) show/hide docs
PC-CT-0015-0007 | PC-CT-0015-0009
Boggs, Erin (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-9000
Fathi, David Cyrus (District of Columbia) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0010 | PC-CT-0015-9000
Lamoreaux, Annette M. (Connecticut) show/hide docs
McGuire, David J. (Connecticut) show/hide docs
PC-CT-0015-0007 | PC-CT-0015-0009
Redman, Renee Colette (Connecticut) show/hide docs
Solnit, Benjamin A. (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0009 | PC-CT-0015-0010 | PC-CT-0015-9000
Tegeler, Philip D. (Connecticut) show/hide docs
PC-CT-0015-0010 | PC-CT-0015-9000
Defendant's Lawyers Lynch, Ann E. (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0007 | PC-CT-0015-9000
O'Neill, Terrance M. (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0007 | PC-CT-0015-9000
Querijero, Carolyn (Connecticut) show/hide docs
Strom, Steven R. (Connecticut) show/hide docs
PC-CT-0015-0001 | PC-CT-0015-0007 | PC-CT-0015-9000

- click to show/hide ALL -

new search
page permalink

- top of page -