WDNY – Eighth Amendment: Downey v. Sheahan

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U.S. District Court, WDNY

Eighth Amendment

Unauthorized Incarceration – Brief Delay in Release

Downey v. Sheahan

15-cv-6129L

Judge Larimer

Background: The plaintiff alleged that five employees of the Five Points Correctional Facility violated his rights by causing him to serve a sentence of incarceration for five days longer than he should have. The defendants moved to dismiss the complaint.

Ruling: The District Court dismissed the complaint. The court held that the brief delay in his release did not rise to an Eighth Amendment violation. Further, the court noted that there are no facts alleged that three of the employees were aware of the underlying facts or that they had anything to do with the events leading up to the additional days of incarceration. Further, there is no indication that the last employee was in any way responsible for the unauthorized detention. The District Court noted that even if there was a constitutional basis for the claim, the defendants would be entitled to qualified immunity.

Ryan Chalres Woodworth of the Woodworth Law firm for the plaintiff; Gary M. Levine of the New York State Office of the Attorney General for the defendant