Case: Smith v. Coughlin

A prisoner at Green Haven Correctional facility was convicted of murder and sentenced to death for killing a corrections officer while serving a life sentence. Immediately after sentencing, he was moved from the general prison population to a unit for condemned persons (""UCP""). He then filed a law suit in the U.S. District Court for the Southern District of New York under 42 U.S.C. § 1983 challenging the conditions of his confinement and seeking injunctive relief. Plaintiff was represented by William Kunsler, among several other lawyers. Specifically, he alleged violations of his First, Fifth, Sixth, Eighth, and Fourteenth Amendment rights as well as violations of state statute and an existing consent decree.

The district court (Judge David N. Edelstein) ruled against the plaintiff on all but one of his claims. Smith v. Coughlin, 577 F.Supp 1055 (S.D.N.Y. Jan. 6, 1983[sic] ). The court first rejected plaintiff's statutory claim saying that the prison officials' interpretation was reasonable and not clearly erroneous. Next, the court held that plaintiff's Eight Amendment claim was without merit. The court held that the prison has a legitimate interest in restricting plaintiff's visits to family and banning him from group masses. As to the latter, the court specifically held that restriction on attendance in group mass did not infringe on his religious freedom. Additionally, it held that plaintiff had no constitutional right to contact visits, and that alternative means of communication with friends existed. The court also rejected plaintiff's Fifth and Fourteenth Amendment due process claims that he had a protected liberty interest in contact with other inmates that had been deprived without due process of law, reasoning that no such constitutional or state protected interest existed. The claim that the transfer without a hearing violated the consent decree in Kozlowski v. Coughlin, 539 F.Supp 852 (S.D.N.Y. 1982) (PC-NY-034) was also rejected as that order did not apply to prisoners in UCP who have different liberty interests. Plaintiff's equal protection claim was also rejected. Finally, the court rejected the Sixth Amendment claim that the totality of the circumstances diminished his physical and mental health to the point of diminishing his access to courts finding that his will had not been broken. However, the court did find that plaintiff's claim that preventing contact with his paralegals working for his attorneys was meritorious, and the policy did violate his constitutional right to access to the courts.

The Second Circuit (Judge Lawrence Warren Pierce) affirmed and remanded the decision of the district court. Smith v. Coughlin, 748 F.2d 783 (2d Cir. 1984). The court noted, however, that after oral argument, but before its opinion was issued, New York courts had declared as unconstitutional the law under which plaintiff was sentenced to die. Accordingly, plaintiff's sentence was vacated and he was moved from UCP, thus making moot his claims for injunctive relief. The only issue to be resolved was an award of damages, which the court of appeals found the district court had erred in failing to award. The Second Circuit held that although compensatory damages cannot be awarded absent proof of actual compensable injury - which here the plaintiff failed to do - nominal damages could still be awarded. Accordingly, it remanded the case to the district court for entry of a nominal award of $1.

It appears from the timeline that this ruling actually came down on January 6, 1984. We presume that the reporter contains a typo.

The docket for this case is not available on PACER, and therefore our information ends with the Nov. 16, 1984 court opinion.