Inmates win constitutional claim against State prison system

The Court of Appeals has upheld a permanent injunction against the New York State prison system, agreeing with the district court that DOCCS did not provide necessary medication to inmates in violation of the Constitution.

The case is Daniels v. Moores, a summary order issued on March 21. The plaintiffs, who obtained class certification, have chronic pain. Under DOCCS's old policy, strict rules guided administration of their medication, but a new policy was later implemented that eased up those restrictions to allow inmates to get their medication even though these pills can be subject to abuse; certain monitoring rules were put in place to prevent such abuse. But the preliminary injunction hearing revealed that the DOCCS was still following the older, more restrictive policy. The trial court ordered DOCCS to comply with the more recent policy.

Under these factual findings, the fact that DOCCS was still adhering to the prior policy did not render the case moot. The agency was not following the new policy. As for the Eighth Amendment issue of whether defendants were depriving plaintiff of access to necessary health care, the trial court found, and the Court of Appeals (Jacobs, Merriam and Calabresi) agrees, that plaintiff were suffering severe pain (a necessary element under the Fourteenth Amendment) and the defendants deprived plaintiffs of the necessary medication with the culpable state of mind, that is, they did so after ignoring plaintiff's complaints of debilitating pain. This kind of deliberate indifference, a legal standard created by the Supreme Court decades ago to give prison doctors and officials latitude to run their facilities without significant and potential meddlesome constitutional oversight, violates the Constitution.

Other procedural issues: the trial court properly granted plaintiffs' application for a class action, not an easy result to achieve with this many potential class plaintiffs. The Court of Appeals also finds the trial court had authority to award plaintiffs' lawyers attorneys' fees for successfully litigating this case. Winning a permanent injunction, as opposed to a mere preliminary injunction (due to a recent Supreme Court case) will get you those fees, as the plaintiffs have achieved an enforceable judgment on the merits, altering the legal relationship between the parties.