Badgley v. Santacroce

A class of incarcerated individuals (the prisoner class) (plaintiffs) sued the Nassau County sheriff, the warden of the Nassau County Correctional Center (NCCC), and two state officials (collectively, the jail officials) (defendants) in federal district court, alleging significant overcrowding at the NCCC. The parties agreed that the jail officials would build new dormitories and restrict the NCCC’s population to a set maximum. If the NCCC reached its population cap, the jail officials could accept only prisoners charged with certain felonies or who were unable or unlikely to be released on bail. The district court entered this consent judgment as a formal court order. However, for years, the jail officials failed to consistently comply. The NCCC’s population frequently exceeded the agreed number—at times exceeding 120 percent of capacity. The prisoner class filed enforcement requests in district court, seeking sanctions. The district court declared the officials’ lack of compliance a disaster and modified the order. More time passed, and the jail officials still failed to comply with the amended order. The prisoner class moved to have the district court hold the sheriff and warden in civil contempt. The sheriff and warden argued they could not refuse to accept individuals that the state courts had ordered them to accept. However, evidence showed that state courts did not direct individuals to specific jails. After several hearings, the district court denied the contempt request, finding that the sheriff and warden had not willfully violated the order, had made every reasonable effort to comply, and could not comply without assistance from state officials. The prisoner class appealed to the United States Court of Appeals for the Second Circuit.