Williams vs. O’Gorman et al.

Case Background

On November 16, 2020, Plaintiff Wonder Williams filed a Solitary Confinement lawsuit in the United States District Court, Northern District of New York(Case number: 9:20cv1417). Judge Chief Judge Brenda K. Sannes and  Magistrate Judge Therese Wiley Dancks presided over the case.

Cause

Wonder Williams endured nearly nine years of solitary confinement in New York state prisons from 2010 to 2019. Prison officials placed the 38-year-old former security worker in administrative segregation immediately upon his entry into DOCCS custody at age 27. This decision stemmed from his alleged involvement in a murder-for-hire plot while at Rikers Island. During his confinement, authorities transferred Williams between Auburn, Five Points, and Mid-State Correctional Facilities, where he spent 23 hours daily in a concrete cell no larger than a parking space.

Prison officials conducted perfunctory 30-day reviews of his administrative segregation status, using identical boilerplate language without considering changed circumstances. Despite maintaining good behavior with only two minor disciplinary infractions (October 2012 and January 2015), officials continued his solitary confinement without providing guidance on improving his status. From December 2017 to February 2019, Williams received no reviews while in a step-down program, though the conditions remained virtually identical to administrative segregation.

Injuries

Williams suffered severe physical and psychological deterioration during his confinement. His physical health declined as he developed a thyroid condition that caused significant weight loss. A fall in the shower in 2013 resulted in chronic back and neck pain. He also experienced persistent migraines, sleep disorders, and developed skin rashes and fungal infections due to unsanitary conditions.

The psychological impact was equally devastating. Williams developed severe anxiety, depression, chronic insomnia, and significant personality changes. The extreme isolation led to social withdrawal, difficulty concentrating, and profound emotional trauma. Prison officials were aware of his declining health through multiple grievances and written complaints but failed to address these serious medical concerns.

Damages

The prolonged solitary confinement inflicted permanent psychological injuries on Williams, causing significant pain and suffering that continues to affect his daily life. His constitutional rights were repeatedly violated through cruel and unusual punishment and lack of due process. The isolation deprived him of basic human needs, including normal human contact, environmental stimulation, adequate physical exercise, proper sleep, nutrition, and meaningful activity. Williams seeks compensatory damages for physical and psychological harm, punitive damages against the defendants, and coverage of attorneys’ fees and associated costs. He also seeks declaratory relief regarding the unconstitutional nature of extended solitary confinement practices.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s): Wonder Williams
    • Counsel for Plaintiff: Ellen M. Dunn| Andrew A. Kunsak | Briana Merritt | Cassandra Liu | Laura Sorice | Leslie Kuhn-Thayer | Michael L. Lisak | Sona De | Tyler J. Domino
  • Defendant(s):James O’Gorman, Deputy Commissioner for Correctional Facilities | John Colvin, Superintendent of Five Points | Matthew Thoms, Superintendent of Mid-State
    • Counsel for Defendants: Ryan W. Hickey| Alexander Powhida

Key Arguments or Remarks by Counsel

Sidley Law firm commented that “This is a landmark decision. It is the first jury verdict, to the firm’s knowledge, on solitary confinement in New York state in a quarter century, and the first time that solitary confinement in New York state prisons was found cruel and unusual under the high standards required to prove an 8th Amendment violation”.

Claims

Williams’ case involves multiple constitutional violations in a Solitary Confinement lawsuit . Under the Fourteenth Amendment, he suffered due process violations. This occurred due to the lack of meaningful reviews of his administrative segregation status. His confinement was rubber-stamped without proper justification. Additionally, there was a failure to provide adequate hearing procedures.

His Eighth Amendment rights were also violated. The violations stemmed from cruel and unusual punishment, deliberate indifference to medical and mental health needs, and inhumane living conditions. The excessive duration of his solitary confinement further contributed to these violations. The case also includes Section 1983 Civil Rights violations. It highlights systemic failures to protect constitutional rights. There was deliberate indifference by prison officials and the implementation of unconstitutional policies and practices.

Defense

The defendants denied all allegations of wrongdoing and constitutional violations in a Solitary Confinement lawsuit . They asserted that the complaint failed to state a valid claim. They argued that they acted under the reasonable belief that their conduct followed established law. This belief, they contended, made them protected by qualified immunity. The defendants claimed the case was barred under res judicata and collateral estoppel principles. They also argued that any state law claims were blocked by various laws, including the Eleventh Amendment.

Additionally, the defendants maintained that they were not personally involved in any alleged violations. They argued that, as a result, they could not be held liable under 42 U.S.C. §1983. They also argued that Williams failed to exhaust all available administrative remedies before filing suit. Furthermore, the defendants claimed that any injuries or damages Williams sustained resulted from other causes or his own conduct, not from their actions.

Jury Verdict

On September 20, 2024, the jury found that Plaintiff Williams proved his Eighth Amendment conditions of confinement claim against Defendant Colvin and Defendant O’Gorman, but not against Defendant Thoms. The jury awarded $1.00 in compensatory damages for each successful claim. The jury also determined that Williams was entitled to punitive damages against both Colvin and O’Gorman. For the claims where the jury found in Williams’ favor, they determined that, while his constitutional rights were violated, he failed to prove actual compensable injuries, resulting in nominal damages of $1.00 per defendant to acknowledge liability in a Solitary Confinement lawsuit .

Court Documents:

Available Upon Request

Press Release:

https://www.sidley.com/en/newslanding/newsannouncements/2024/09/sidley-wins-unanimous-civil-rights-verdict-in-jury-trial