Second Circuit Rejects Qualified Immunity Challenge to Case Against DOCCS Officials

  • April 13, 2023

On April 4, 2023, the U.S. Court of Appeals for the Second Circuit issued an important ruling in favor of firm client Michael Matzell, rejecting an attempt by New York State prison officials to claim qualified immunity from Mr. Matzell’s federal civil rights case.

Mr. Matzell filed the lawsuit in 2020 on behalf of himself and a class of individuals who were denied participation in the Shock Incarceration Program (“Shock”) while they were incarcerated by the New York State Department of Corrections and Community Supervision (“DOCCS”), even though their participation was court-ordered. Mr. Matzell’s sentence included Shock, pursuant to New York State’s Drug Law Reform Act of 2009 (“DLRA”), which gave sentencing judges the authority to order Shock participation.

The Second Circuit denied the DOCCS officials’ bid to dismiss Mr. Matzell’s lawsuit. It held that DOCCS officials “exceeded and abused their governmental authority by ignoring the Court’s sentencing order and the DLRA’s plain statutory language.” It also found that “Matzell plausibly alleged that Defendants’ actions rose to the level of deliberate indifference in violation of his substantive due process rights” and that “Matzell plausibly alleged that Defendants’ actions were egregious, shocking to the conscience, and unreasonable.”

By ignoring court orders, DOCCS officials acted outside the bounds of their legal authority. They also denied Mr. Matzell and others the benefits of Shock, including early release from prison, as well as substance abuse treatment, therapy, education, and other reintegration services. DOCCS caused Mr. Matzell to serve an additional 506 days in prison that he would not have had to serve if he had been rightfully enrolled in Shock.

ECBAWM partner Debra L. Greenberger argued the case before the Second Circuit. She was joined on the brief by Katherine R. Rosenfeld and Vivake Prasad.