Standards.

U.S. District Court

PROFESSIONAL STANDARDS

Benjamin v. Fraser. 161 F.Supp.2d 151 (S.D.N.Y. 2001). Department of Corrections officials who had entered into a consent decree governing conditions for pretrial detainees in New York City jails moved for the immediate termination of those decrees under the provisions of the Prison Litigation Reform Act (PLRA). The consent decree involved fourteen jails that housed over 10,000 inmates. The district court terminated some provisions of the decree, including those involving inmate correspondence and law libraries. The court held a hearing on the issues of environmental health and personal hygiene supplies.

The court found that temperature extremes violated due process, noting that extremes of temperature present health risks as well as discomfort. One expert testified that the human comfort zone is between 67 and 78 degrees Fahrenheit, but because inmates are for the most part sedentary, their general comfort zone is between 72 and 78 degrees. The Department of Corrections had adopted the minimum standards established in the New York City Health Code: between October 1 and May 31st between 0600 and 2200 hours a temperature of at least 68 degrees F when outside temperatures fall below 55 degrees F, and between 2200 and 0600 at least 55 degrees F if the outside temperature falls below 40 degrees F. The court found that "credible evidence tends to show that air temperatures in the Department's jails do not meet constitutional standards." District Judge Beer stated that a Department report that measured temperatures on April 24 and 25, 2000, "does nothing to assuage my concerns that detainees are being subjected t o constitutionally indefensible air temperatures" because the survey was conducted on days when the outside temperature was moderate. The judge also noted that the Department's maintenance records showed numerous references to reports of no heat in Department facilities.

State health cede violations in the jails' food service were not found to rise to the level of a violation of pretrial detainees' due process rights, where sanitary practices were adequate and no detainee had suffered a reported incident of food-borne illness.

The court noted that adequate lighting is one of the fundamental attributes of adequate shelter. Lighting problems can be traced to several problems, according to the court: (1) non-working light fixtures; (2) inadequate light bulb wattage; and (3) obstructed light shields. The court concluded [pun intended?]: "In light of the above, it is clear that detainees in the Department's jails, with the exception of ARDC and AMKC, are subjected to constitutionally inadequate light." The court noted the standards of the American Correctional Association in its decision. The court directed the parties to submit recommendations for prospective relief and suggested that they look into the foot candle standards maintained within ARDC and AMKC as an example of constitutionally sufficient lighting. Lighting was found to be deficient in two medical areas and were placed under continuing court supervision.

The court found that excessive noise may violate the Constitution if it threatens inmates' mental health or deprives them of sleep. The court cited the standards of the American Public Health Association (APHA) and the American Correctional Association (ACA) which set maximum noise levels at 70 decibels during the daytime and 45 decibels at night. Excessive noise was measured in one facility, caused by diesel generators that were scheduled to be decommissioned. The court ordered the parties to submit recommendations for prospective relief at two facilities. (New York City Department of Corrections)