Julius Bryant filed a pro-se lawsuit in the U.S. District Court for the Southern District of New York against the New York Department of Corrections on April 22, 1994, seeking damages for deliberate indifference to his medical needs for his disabling back condition while he was an inmate at Green Haven Correctional Facility ("Green Haven"). Following a jury trial, the action was settled on February 20, 1998, by an agreement which called for plaintiff's admission to the Unit for the Physically Disabled ("UPD") at Green Haven and his entitlement to the "benefits of treatment at the UPD in accordance with the rules and regulations of the prison and the statement of the Department of Corrections." The agreement contained a clause recognizing the parties' right to bring to the court's attention any violation of the agreement, and the court's power to issue any order necessary to ensure the agreement is followed.

The plaintiff later filed a motion for contempt against the Department of Corrections, alleging violation of the settlement agreement; Defendants moved to terminate the agreement, alleging it was a violation of the Prisoner Litigation Reform Act.

On April 21, 1999, the U.S. District Court for the Southern District of New York (Judge Thomas P. Griesa) denied plaintiff's motion on grounds that contempt is an inappropriate remedy when the settlement agreement is not a court order or decree. Bryant v. Coughlin, No. 94-2940, 1999 WL 232705 (S.D.N.Y. Apr. 21, 1999).

Judge Griesa also denied defendants' motion to terminate the agreement. Defendants had asserted that the agreement was properly construed as a consent decree, and as such, that it violated the terms of the PLRA, which prohibits the court from issuing prospective relief. Judge Greisa found that the agreement was a private settlement agreement but that it was still inconsistent with the PLRA. However, Judge Griesa refused to terminate the agreement, which had been in effect for more than a year. Rather, he held that the proper remedy was to amend the offending clause of the agreement.

Plaintiff later claimed that defendants violated the agreement when they moved him from the UPD to Shawangunk Correctional Facility. On October 29, 1999, Judge Griesa rejected plaintiff's motion, finding that nothing in the agreement prevented prison authorities from moving plaintiff to protect his safety. Bryant v. Coughlin, No. 94-2940, 1999 WL 983865 (S.D.N.Y. Oct. 29, 1999). This ruling was affirmed in an unpublished opinion by the Second Circuit Court of Appeals on March 9, 2001. Bryant v. Coughlin, 5 Fed. Appx. 45, No. 00-0020, 2001 WL 246042 (2d. Cir. Mar. 9, 2001).

Megan Raynor - 01/23/2006


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