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Ayers v. Coughlin
New York Court of Appeals
530 N.E.2d 373 (1988)
New York had a dual correction system made up of county jails and state prisons. State defendants who would eventually be sentenced to prison could be held in a county jail until they were convicted and sentenced. New York State Criminal Procedure Law 430.20(1) (CPL 430.20(1)) provided that when a prison sentence is imposed, a defendant must be transferred to a state prison forthwith. Due to prison overcrowding, the New York State Department of Correctional Services (the department) had a policy of delaying its acceptance of state prisoners from county jails for six months or more according to regulations it promulgated itself. A group of county sheriffs (collectively, the sheriffs) (plaintiffs), including James Ayers, filed a lawsuit in state court seeking to compel the commissioner of the department (the commissioner) (defendant), Thomas Coughlin, to accept state prisoners from county jails within 48 hours of their sentencing. The New York Supreme Court held that due to its use of the term forthwith, CPL 430.20(1) required the department to accept state prisoners within 10 days of their sentencing. The commissioner appealed. The appellate division held that the supreme court could not order the department to accept state prisoners within 10 days of their sentencing. Instead, the appellate division held that the department could continue to use its own regulations to determine when to transfer a state prisoner. The sheriffs appealed.
Rule of Law
Holding and Reasoning (Kaye, J.)
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