Benjamin v. Malcolm

LASKER, Senior District Judge.

This class action concerns overcrowding in the House of Detention for Men on Rikers Island (“HDM”). Three years after relief was granted against the state defendants in this case, the United States Supreme Court decided the landmark case of Pennhurst State School and Hospital v. Halderman, 465 U.S. 89, 104 S.Ct. 900, 79 L.Ed.2d 67 (1984) (“Pennhurst II”), holding that federal courts have no jurisdiction to enjoin state officials on the basis of a state law violation. Relying on that authority, Governor Mario Cuomo1 and Thomas A. Coughlin III, Commissioner of the…