Darnell v. City of New York, 2017 U.S. App. LEXIS 2911

Twenty pretrial detainees in a single complaint alleged unconstitutional conditions at a Brooklyn Central Booking holding facility (BCB) and supervisory NYPD officials under §1983.
BCB operated as a temporary pre-arraignment holding unit where detainees were held 10–24 hours; no one remained beyond 24 hours.
Defendants included the City of New York, NYPD Captains Kobetitsch and Tobin, who supervised BCB operations and daily tours.
Plaintiffs claimed nine categories of deplorable conditions (overcrowding, unusable toilets, sanitation, infestation, lack of hygiene items, nutrition, extreme temperatures/ventilation, sleep deprivation, crime/intimidation) and asserted deliberate indifference to due process rights.
District Court granted summary judgment, holding no objective deprivation or deliberate indifference; Kingsley and Willey decisions were not analyzed; the case was appealed for reconsideration and remand.
The Second Circuit affirmed in part, vacated in part, and remanded for individual claims analysis, adopting an objective standard for deliberate indifference under the Fourteenth Amendment and remanding related issues (punitive intent, qualified immunity, Monell).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for deliberate indifference under Fourteenth Amendment post-Kingsley	Kingsley allows objective standard for due process.	Caiozzo subjective standard should apply.	Deliberate indifference = objective standard.
Whether duration/severity of conditions can show a due process violation despite no long-term injury	Appalling BCB conditions over time create deprivation.	Only injuries or extended duration matter; no severe injury shown.	Must assess severity and duration case-by-case; not a bright-line rule.
Whether aggregate conditions at BCB constitute an objective deprivation	Combined conditions severely degraded dignity and safety.	Single issues insufficient without long-term injury.	Yes, conditions may be jointly oppressive; individual disputes remain.
Subjective prong after Kingsley for deliberate indifference claims	Officers knew of conditions and disregarded risks.	Defendants lacked knowledge of unconstitutional conditions.	Subjective standard redefined as objective under Kingsley.
Remand considerations: punitive intent, qualified immunity, Monell liability	District Court erred in dismissing these based on lack of objective deprivation.	Standards unsettled; should be addressed with new framework.	Vacated; remanded for proper consideration under new standard.

Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (pretrial detainee standard for due process is objective for excessive force and conditions claims)
Willey v. Kirkpatrick, 801 F.3d 51 (2d Cir. 2015) (severity and duration govern unsanitary/limited-condition claims; no fixed duration rule)
Caiozzo v. Koreman, 581 F.3d 63 (2d Cir. 2009) (applies subjective standard to deliberate indifference under Fourteenth Amendment until Kingsley; later overriden conceptually by Kingsley for due process)
Walker v. Schult, 717 F.3d 119 (2d Cir. 2013) (multifactor test: mutually enforcing conditions; aggregate deprivation)
Jabbar v. Fischer, 683 F.3d 54 (2d Cir. 2012) (sanitation/health risks as potential objective deprivation under Fourteenth Amendment)
Benjamin v. Fraser, 343 F.3d 35 (2d Cir. 2003) (due process rights of pretrial detainees; foundation for Fourteenth Amendment analysis)
Bell v. Wolfish, 441 U.S. 520 (1979) (due process framework for pretrial detainees; objective evaluation for legitimate purpose)
Rhodes v. Chapman, 452 U.S. 337 (1981) (informs contextual understanding of confinement severity and space)
LaReau v. MacDougall, 473 F.2d 974 (2d Cir. 1972) (early recognition of health/mental danger in confinement)
Walker v. Wilson, not provided (not provided) (illustrative on combined-deprivation framework)