Vincent v. Yelich Earley v. Annucci
718 F.3d 157
| 2d Cir. | 2013Background
- Plaintiffs, former New York State prisoners, allege DOCS and Parole Division officials unlawfully imposed PRS terms administratively without court-imposed orders.
- Jenna's Law created mandatory post-release supervision as part of determinate sentences, sometimes not stated in commitment orders.
- Earley v. Murray (Earley I/II) held administrative imposition of PRS not pronounced by the court violates due process; AEDPA context addressed habeas relief.
- District courts dismissed the complaints as to most defendants on qualified-immunity grounds, focusing on pre- and post-Earley I developments.
- This court vacates the dismissal as to Annucci (DOCS Executive Deputy Commissioner) and remands for further proceedings, affirming as to other defendants.
- Record shows some plaintiffs had PRS imposed or enforced after Earley I, and some were reimprisoned for PRS violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Earley I clearly establish the right against administrative PRS under qualified immunity? | Vincent/JJohnson/Earley contend Earley I foreclosed admin PRS not court-imposed. | Annucci/defendants argue Earley I was AEDPA habeas context only, not clearly established for qualified immunity. | Earley I clearly established the unconstitutionality of admin PRS not imposed by the court. |
| Is Annucci entitled to qualified immunity on damages claims at this stage? | Annucci violated clearly established rights by enforcing admin PRS despite Earley I. | Annucci acted within a reasonable reliance on state practice and later adjustments; record insufficient for immunity denial. | Annucci is not entitled to qualified immunity on the current record; dismissal vacated as to Annucci |
| Are the other DOCS/Parole defendants entitled to qualified immunity on these claims? | Defendants knew PRS lacked court-imposed basis and continued enforcement post-Earley I. | Post-Earley I decisions and state practices supported immunity for pre-Earley I actions; not clearly established for all defendants. | Affirmed as to other defendants; qualified immunity upheld for those defendants on damages claims |
Key Cases Cited
- Earley v. Murray, 451 F.3d 71 (2d Cir. 2006) (administrative PRS not pronounced by court violates due process)
- Earley v. Murray, 462 F.3d 147 (2d Cir. 2006) (rehearing denied; further discussion of PRS)
- Wampler, 298 U.S. 460 (S. Ct. 1936) (only the court's judgment controls sentence; administrative modifications invalid)
- Greene v. United States, 358 U.S. 326 (S. Ct. 1959) (sentence rule and prosecutorial limits)
- Jones v. Cunningham, 371 U.S. 236 (S. Ct. 1963) (parole constitutes custody for habeas purposes)
- Harlow v. Fitzgerald, 457 U.S. 800 (S. Ct. 1982) (qualified immunity framework for government officials)
- Anderson v. Creighton, 483 U.S. 635 (S. Ct. 1987) (clearly established standard for rights at the time of conduct)
- Scott v. Fischer, 616 F.3d 100 (2d Cir. 2010) (distinguishes AEDPA context from qualified-immunity analysis)
- Sudler v. City of New York, 689 F.3d 159 (2d Cir. 2012) (scope of qualified-immunity protections for municipal officials)