Brief of Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, NY County Defender Services, and Queens Defenders as Amici Curiae in Support of Plaintiffs’ Motion for Contempt and Application for Appointment of a Receiver
The Bronx Defenders
Brooklyn Defender Services
Neighborhood Defender Service of Harlem
New York County Defender Services
Queens Defenders
SimpleOriginal

Summary

Amici argue that pervasive violence and dysfunction in New York City jails inflict severe physical and psychological trauma, undermine fair criminal proceedings, and warrant contempt sanctions and appointment of a receiver.

2023 | Federal Juristiction

Brief of Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, NY County Defender Services, and Queens Defenders as Amici Curiae in Support of Plaintiffs’ Motion for Contempt and Application for Appointment of a Receiver

Keywords excessive force; New York City jails; public defenders; constitutional rights; DOC custody; Rikers Island; legal services; violence; dysfunction; Consent Decree

INTRODUCTION AND STATEMENT OF INTEREST

Eight years after this Court entered its Consent Decree mandating significant reforms to reduce the use of excessive force in New York City jails, the people held in those jails are increasingly subject to intolerable and sometimes deadly violence and dysfunction. Amici curiae The Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, New York County Defender Services, and Queens Defenders are not-for-profit public defender offices that provide multidisciplinary legal services along with social work and advocacy support to low-income New Yorkers. As public defenders, amici collectively represent hundreds of thousands of people each year charged in New York City’s criminal courts, including thousands each year who are detained or incarcerated in the New York City jail system while they fight their cases in court or serve a sentence of a year or less. The majority of the people we represent are Black and brown New Yorkers from under-resourced neighborhoods. As public defenders, amici have unique insight and experience regarding the humanitarian crisis unfolding at New York City Department of Corrections (“DOC” or the “Department”) facilities. For years, amici have seen New York City jails plunge deeper and deeper into an abyss of chaos and cruelty. Yet what amici have witnessed in the last two years is alarming beyond measure: an increasingly pervasive culture of hostility and aggression within DOC causing outrageous violence, suffering, and neglect.

Amici respectfully submit this brief in support of Plaintiffs’ Motion for Contempt and Application for Appointment of a Receiver (ECF No. 601). Amici have a substantial and compelling interest in advocating for the safety and constitutional rights of people in DOC custody. In this brief, amici offer insights from their experience as public defenders to highlight how the Department’s excessive force and hyper-confrontational culture impacts people in custody and the severe consequences of exposure to normalized violence and disorder. The stories below of people who have suffered enormous physical and psychological harm as a result of the chaos and dysfunction in New York City jails are but a small sampling of the myriad harms that people in DOC custody endure on a daily basis. There is no question that DOC is unwilling and unable to protect the people in its custody and their constitutional rights, or to undertake the reforms needed to comply with core provisions of the Consent Decree and other Court-ordered relief.

Amicus curiae The Bronx Defenders (“BxD”) is a non-profit provider of innovative, holistic, client-centered criminal defense, family defense, civil legal services, and social work support to indigent people in the Bronx. Each year, BxD’s advocates defend thousands of lowincome Bronx residents in criminal cases—including individuals who are held in custody at Rikers Island—and civil, family, and immigration cases, and reaches hundreds more through outreach programs and community legal education.

Amicus curiae Brooklyn Defender Services (“BDS”) is one of the largest public defense offices in New York State, representing low-income people in nearly 22,000 criminal, family, civil, and immigration proceedings each year. Its staff consists of specialized attorneys, social workers, investigators, paralegals, jail services specialists, and administrative staff who are experts in their individual fields. For over twenty-five years, BDS has worked, in and out of court, to protect and uphold the rights of individuals and to change laws and systems that perpetuate injustice and inequality.

Amicus curiae Neighborhood Defender Service of Harlem (“NDS”) is a community-based public defender office. Since 1990, NDS has sought to improve the quality and depth of criminal, family, and civil defense for those in Harlem and Northern Manhattan who cannot afford an attorney. NDS accomplishes this by providing holistic, cross-practice representation to its clients.

Amicus curiae New York County Defender Services (“NYCDS”) is a public defender office serving indigent clients in the borough of Manhattan in New York City since 1997. NYCDS provides comprehensive legal advocacy for its clients while promoting systemic reforms to the criminal legal system. Its diverse staff of attorneys, social workers, investigators, paralegals, jail advocates, and support staff is committed to protecting the rights of its clients both inside and out of the courtroom. On any given day, approximately 300 NYCDS clients are confined to the custody of DOC.

Amicus curiae Queens Defenders provides free, high-quality legal representation to individuals accused of crimes in Queens County. Since 1996, Queens Defenders’ highly skilled attorneys have represented over 450,000 people and handle major trials and homicides, work with clients involved in Queens treatment courts, and represent cases involving domestic violence, youth charged with felonies, and immigrants facing criminal charges.

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Summary

Eight years following a court order for significant changes to reduce excessive force in New York City jails, individuals in these facilities are increasingly exposed to severe and sometimes fatal violence and disorder. Five non-profit public defender organizations—The Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, New York County Defender Services, and Queens Defenders—collectively represent thousands of low-income New Yorkers each year who are detained in the city's jail system. A majority of these individuals are Black and brown New Yorkers from communities with limited resources.

These organizations, acting as "amici curiae," have a unique perspective on the crisis within the New York City Department of Corrections (DOC) facilities. For years, these defenders have observed a deepening state of chaos and cruelty in the jails. Over the past two years, they have witnessed an alarming increase in hostility and aggression within the DOC, leading to widespread violence, suffering, and neglect.

The amici respectfully support the Plaintiffs' Motion for Contempt and Application for Appointment of a Receiver (ECF No. 601). They have a strong interest in protecting the safety and constitutional rights of individuals held in DOC custody. This brief uses the defenders' experiences to highlight how the Department's excessive force and confrontational culture affect those in custody and the serious consequences of being exposed to constant violence and disorder.

The provided accounts of individuals who have suffered significant physical and psychological harm due to the dysfunction in New York City jails represent only a small portion of the daily harm experienced by people in DOC custody. It is clear that the DOC is unwilling and unable to protect individuals in its care, uphold their constitutional rights, or implement the necessary reforms to comply with the Consent Decree and other court orders.

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Introduction and Statement of Interest

Eight years after a court order aimed at reducing excessive force in New York City jails, individuals held in these facilities face increasing violence and dysfunction. Several public defender organizations, known as amici curiae, are submitting this brief. These organizations include The Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, New York County Defender Services, and Queens Defenders. They are non-profit groups that provide legal and social support to low-income New Yorkers. Each year, they represent thousands of people in New York City's criminal courts. Many of these individuals are detained in the city's jail system while awaiting trial or serving short sentences. A majority of those represented are Black and brown New Yorkers from communities with limited resources.

These public defender groups have direct experience with the crisis in the New York City Department of Corrections (DOC) facilities. They have observed the jails becoming more chaotic and cruel over the years. In the last two years, they have witnessed an alarming increase in hostility and aggression within the DOC, leading to significant violence, suffering, and neglect.

The amici respectfully support the Plaintiffs' request for the court to find the DOC in contempt and to appoint an independent party to manage the jails. The amici have a strong interest in protecting the safety and constitutional rights of people in DOC custody. This brief uses the public defenders' experiences to show how the DOC's use of excessive force and confrontational culture harms those in custody. It also highlights the serious consequences of being exposed to constant violence and disorder. The individual stories shared in this brief are only a few examples of the many harms experienced daily by people in DOC custody. It is clear that the DOC is unwilling and unable to protect those in its care or to implement the necessary reforms to comply with the court's original order.

The Bronx Defenders (BxD) is a non-profit organization that provides comprehensive legal services, including criminal defense, family defense, civil legal services, and social work support, to low-income residents of the Bronx. Annually, BxD advocates represent thousands of Bronx residents in various legal cases, including individuals held at Rikers Island. They also engage with hundreds more through community outreach and legal education programs.

Brooklyn Defender Services (BDS) is one of New York State's largest public defense offices. It represents low-income individuals in nearly 22,000 criminal, family, civil, and immigration cases each year. Its staff includes specialized attorneys, social workers, investigators, paralegals, jail services specialists, and administrative staff. For over twenty-five years, BDS has worked both inside and outside the courtroom to protect individual rights and advocate for changes to laws and systems that perpetuate injustice.

Neighborhood Defender Service of Harlem (NDS) is a community-based public defender office. Since 1990, NDS has aimed to improve the quality of criminal, family, and civil defense for individuals in Harlem and Northern Manhattan who cannot afford legal representation. NDS achieves this by providing holistic, integrated legal services to its clients.

New York County Defender Services (NYCDS) is a public defender office serving indigent clients in Manhattan since 1997. NYCDS offers comprehensive legal advocacy while also promoting systemic reforms within the criminal legal system. Its diverse team of attorneys, social workers, investigators, paralegals, jail advocates, and support staff is committed to protecting clients' rights both in and out of court. Approximately 300 NYCDS clients are held in DOC custody on any given day.

Queens Defenders provides free, high-quality legal representation to individuals accused of crimes in Queens County. Since 1996, Queens Defenders' attorneys have represented over 450,000 people. They handle major trials and homicides, work with clients in Queens treatment courts, and represent cases involving domestic violence, youth charged with felonies, and immigrants facing criminal charges.

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Introduction and Statement of Interest

Eight years ago, a court order required significant changes to reduce excessive force in New York City jails. However, people held in these jails are now facing increasing, unacceptable, and sometimes deadly violence and disorder. Several non-profit public defender organizations are involved in this issue. These organizations include The Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, New York County Defender Services, and Queens Defenders. They provide various legal and social services to low-income New Yorkers.

These public defenders collectively represent many thousands of people each year in New York City's criminal courts. This includes thousands who are held in the city's jail system while their cases proceed or while they serve short sentences. Most of the people represented are Black and brown New Yorkers from communities with limited resources. These public defender groups have unique knowledge and experience regarding the serious problems in New York City Department of Corrections (DOC) facilities. For years, they have observed the jails becoming more chaotic and cruel. However, what has happened in the last two years is extremely alarming: an increasingly widespread atmosphere of hostility and aggression within the DOC, leading to severe violence, suffering, and neglect.

These public defender organizations are formally supporting a motion that asks the court to find the DOC in contempt and to appoint a receiver to manage the jails. They have a strong interest in protecting the safety and constitutional rights of people held by the DOC. In their brief, they share insights from their experience to show how the DOC's excessive force and aggressive culture affect people in custody. They also highlight the serious results of being exposed to normalized violence and disorder. The stories shared, detailing significant physical and mental harm due to the chaos in New York City jails, are just a small example of the many harms people in DOC custody experience daily. There is clear evidence that the DOC is unwilling and unable to protect those in its custody and their rights, or to make the necessary changes to follow the court's orders.

The Bronx Defenders (BxD) is a non-profit organization. It offers innovative, holistic, and client-focused criminal defense, family defense, civil legal services, and social work support to low-income individuals in the Bronx. Each year, BxD's advocates represent thousands of low-income Bronx residents in criminal cases, including those held at Rikers Island, as well as in civil, family, and immigration cases. The organization also reaches hundreds more through community outreach and legal education programs.

Brooklyn Defender Services (BDS) is one of the largest public defense offices in New York State. It represents low-income individuals in nearly 22,000 criminal, family, civil, and immigration cases annually. Its staff includes specialized attorneys, social workers, investigators, paralegals, jail services specialists, and administrative personnel, all experts in their fields. For over 25 years, BDS has worked both inside and outside of court to protect individual rights and to change laws and systems that promote injustice and inequality.

Neighborhood Defender Service of Harlem (NDS) is a public defender office based in the community. Since 1990, NDS has aimed to improve the quality and depth of criminal, family, and civil defense for those in Harlem and Northern Manhattan who cannot afford a lawyer. NDS achieves this by providing comprehensive, cross-practice representation to its clients.

New York County Defender Services (NYCDS) is a public defender office that has served low-income clients in Manhattan, New York City, since 1997. NYCDS provides thorough legal advocacy for its clients and also promotes larger reforms in the criminal legal system. Its diverse staff of attorneys, social workers, investigators, paralegals, jail advocates, and support staff is dedicated to protecting the rights of clients both in and out of court. On any given day, approximately 300 NYCDS clients are held in DOC custody.

Queens Defenders offers free, high-quality legal representation to individuals accused of crimes in Queens County. Since 1996, Queens Defenders' skilled attorneys have represented over 450,000 people. They handle major trials and homicides, work with clients in Queens treatment courts, and represent cases involving domestic violence, youth charged with felonies, and immigrants facing criminal charges.

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A Problem in New York City Jails

For eight years, a court order has tried to stop too much force in New York City jails. But people in these jails are still getting hurt and sometimes dying. Five groups that help people with legal problems see this firsthand. These groups are called "amici curiae."

Who These Groups Are

These groups help people who do not have a lot of money. They help thousands of people each year in New York City courts. Many of these people are Black and brown and come from neighborhoods that do not have many resources. Some of them are held in New York City jails while their cases are handled.

What the Groups Have Seen

These groups have seen that things in the jails are getting worse. They have seen a lot of anger and fighting. This has led to people getting seriously hurt and not being cared for. The groups believe the jail system is not able to keep people safe or respect their rights.

Why They Are Speaking Out

The groups are asking the court to make changes. They want the court to get involved because the jail system is not following the original court order. These groups have many stories of people who have been seriously hurt in the jails. They believe the jail system is not willing or able to fix these problems.

The Groups Involved

Each of these groups works to help people. The Bronx Defenders helps people in the Bronx. Brooklyn Defender Services helps people in Brooklyn. Neighborhood Defender Service of Harlem helps people in Harlem. New York County Defender Services helps people in Manhattan. Queens Defenders helps people in Queens. They all work to protect the rights of people in jail.

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Footnotes and Citation

Cite

Brief of the Bronx Defenders, Brooklyn Defender Services, Neighborhood Defender Service of Harlem, New York County Defender Services, and Queens Defenders as Amici Curiae in Support of Plaintiffs’ Motion for Contempt and Application for Appointment of a Receiver, Nunez v. City of New York, No. 11-cv-5845 (S.D.N.Y. Dec. 1, 2023)

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