453 F.2d 12 (2d Cir. 1971)
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This legal case involves Attica Correctional Facility inmates who sued the Governor of New York and others. The case was heard in the United States Court of Appeals, Second Circuit, and a decision was made on December 1, 1971. The appeal was based on federal jurisdiction under 42 U.S.C. § 1983 and 28 U.S.C. § 1343. The court affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The legal action is based on events that occurred after the New York State regained control of Attica Correctional Facility on September 13, 1971, following a four-day inmates' riot. The State regained control by armed force, resulting in the death of an additional 29 inmates and 10 hostages, injuries to numerous others, and destruction of property.
On September 13, 1971, a group of lawyers filed a lawsuit on behalf of all Attica inmates, seeking access to the facility and a preliminary injunction against prisoner interrogation. The request was denied by Judge Curtin on September 14, as no investigations had been initiated by correctional personnel at Attica. Governor Rockefeller appointed a panel of five impartial observers to examine conditions at Attica, and Judge Curtin denied preliminary injunctive relief due to a lack of immediate need. Deputy Attorney General Robert E. Fischer investigated crimes at Attica and interviewed inmates.
Judge Curtin reopened the application for temporary injunctive relief due to counsel being denied access to Attica. Defendants distributed a notice to inmates informing them of their right to speak to a lawyer before being interrogated. The district court denied the plaintiffs' request for an injunction against interrogating prisoners without counsel present, citing the availability of facilities for attorney-client interviews and the option to raise objections in state court.
Further hearings were held to receive additional testimony from witnesses, including the superintendent of Attica, a member of the Goldman Panel, a member of the New York State Assembly, and six inmates. The only testimony presented to support the plaintiffs' claim of unconstitutional interrogations of prisoners was from an inmate named Charles Colvin and Superintendent Mancusi. However, the court affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The lower court erred in denying the plaintiffs' request for an injunction against interrogating prisoners without counsel present.
The Attica inmates alleged cruel and inhumane treatment by guards and correctional personnel, and the federal court acknowledges the need for intervention due to specific claims of ongoing physical abuse. The district court erred in denying preliminary injunctive relief against physical abuse, beatings, and similar conduct by prison guards. The court ordered a preliminary injunction against physical abuse, torture, beatings, or other forms of brutality, or threatening such conduct. The state may choose to give Miranda warnings to some and not to others based on who would serve as a witness and who might be a defendant. Claims of failure to observe the Miranda warning should be handled by the appropriate state tribunal. The arbitrary deprivation of "good time" credits in the New York prison system may inhibit the voluntariness of an inmate's choice to seek or not seek counsel.
The case concerns an inmate's right to consult with counsel before being interrogated by state officials. The dismissal of the claim for permanent relief was an error, and the case should be treated as a class action for the limited purposes of brutality and the right to counsel. The case should be remanded for findings, and the hearings on the application for relief should be combined and held promptly. Harris v. New York allows the use of involuntary confessions for impeachment.
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