In 1984, female inmates at the Bedford Hills Correctional Facility in New York filed a lawsuit under 42 U.S.C. § 1983 against the New York State Department of Corrections in the U.S. District Court for the Southern District of New York. The inmates, represented by attorneys from the New York Legal Aid Society's Prisoners' Rights Project, alleged that their constitutional rights had been violated by poor dental care at the prison, and they asked the court for declaratory and injunctive relief.
On August 29, 1985, the U.S. District Court for the Southern District of New York (Judge Shirley Wohl Kram) certified the plaintiffs as a class, holding that declaratory and injunctive relief was appropriate to the class as a whole. Dean v. Coughlin, 107 F.R.D. 331 (S.D.N.Y. Aug. 29, 1985).
On December 3, 1985, district court (Judge Kram) granted a preliminary injunction to the plaintiffs, ordering the defendants to provide adequate dental care to inmates with serious dental needs. Specifically, the court ordered the defendants to provide a dental access system assuring prompt diagnosis and treatment for inmates with serious dental needs, timely follow-up care, and elimination of backlogs in treatment. Refusing to be more specific regarding the terms of the injunction, the court stated its expectation that the defendants and plaintiffs would work out terms for compliance with this injunction. Dean v. Coughlin, 623 F.Supp. 392 (S.D.N.Y. 1985).
On April 1, 1986, the district court (Judge Kram) issued a more detailed order implementing the preliminary injunction, noting that the defendants had failed to even attempt to improve dental services at Bedford Hills. The court required that a priority system must be set for dental care and that all inmates be given an opportunity to have a dental examination to determine their treatment priorities. The court further laid out requirements for a dental sick-call system, an appointment and follow-up system, treatment deadlines for non-emergency patients, dental emergency procedures, dental record keeping, and reporting. Dean v. Coughlin, 633 F.Supp. 308 (S.D.N.Y. 1986). The defendants appealed.
On October 28, 1986, the U.S. Court of Appeals for the Second Circuit (Judge Walter Roe Mansfield, Judge Amalya Lyle Kearse, and Judge Ralph K. Winter, Jr.) vacated the district court's decision and remanded the case, holding that the district court had abused its discretion by specifying in detail the system of dental care to be provided. The circuit court reasoned that the district court should have instead used the New York State Department of Corrections' plan as a guide, subject to minor modifications. Dean v. Coughlin, 804 F.2d 207 (2nd Cir. 1986).
On February 26, 1987, the parties entered into a settlement, which the district court (Judge Kram) approved as a consent decree on June 17, 1987. The consent decree provided for dental care regulations in the areas of treatment priorities, dental emergencies, dental sick call, follow-up care, staffing, record-keeping, and compliance supervision.
In 1988, the defendants informed the plaintiffs that the plaintiffs' expert, a dentist named Dr. William Byland, was illegally practicing dentistry because he was not licensed to practice in New York. The plaintiffs asked the district court for a protective order to enjoin the defendants from prosecuting Byland on criminal charges, arguing that the defendants had attempted to intimidate him by threatening criminal prosecution. On July 12, 1989, the district court (Judge Kram) denied the plaintiffs' motion, holding that there was insufficient evidence to find that the defendants had attempted to intimidate or prosecute Byland. Dean v. Coughlin, 1989 WL 82421 (S.D.N.Y. July 12, 1989). We have no further information on the proceedings in this case.Kristen Sagar - 08/13/2007