Second Circuit – Due Process: Santiago v. Fischer

Listen to this article

United States Court of Appeals for the Second Circuit

 Due Process — Post-release supervision — Limitation of liability

Santiago v. Fischer

23-814(L)

Judges Lynch, Carney, and Menashi

Background: The plaintiff alleged that state officials violated his constitutional rights by enforcing terms of his post-release supervision that were previously deemed unconstitutional via Earley v. Murray, 451.F.3d 71 (2d Cir. 2006). At trial, the defendants sought to introduce evidence that legal and administrative impediments prevented the resentencing of the plaintiff. Thus, reducing the liability of the defendants for failing to achieve the resentencing. The evidence was barred. After a jury returned a verdict in favor of the plaintiff, the defendant’s motion for a new trial was denied.

Ruling: The Second Circuit reversed. The court held that it was an abuse of discretion to bar the evidence of impediments. Furthermore, it was in error to deny the motion for a new trial.

Blair J. Greenwald, assistant solicitor general, for the defendants-appellants-cross-appellees; Rob Rickner, of Rickner PLLC, for the plaintiff-appellee-cross-appellant.

Oral argument audio