Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, No. 19-1778 (2d Cir. 2020)
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The Second Circuit vacated the district court's dismissal of plaintiff's complaint against the BOP and Warden Quay in an action alleging that defendants' curtailment of inmate-attorney visits at the MDC in early 2019 violated the Administrative Procedure Act, and the constitutional right to counsel under the Sixth Amendment.
The court held that the district court erred in dismissing plaintiff's APA claim by failing to consider applicable BOP regulations in its zone-of-interests analysis. Furthermore, the district court misconstrued plaintiff's Sixth Amendment claim. Plaintiff brought this claim under the federal courts' inherent equitable powers, but the district court treated the claim as purporting to arise directly under the Sixth Amendment. The court thought it was prudent to defer ruling on the merits of the Sixth Amendment claim because plaintiff raised novel questions of constitutional law. Accordingly, the court remanded for further proceedings and directed the district court to consider appointing a master to mediate the parties' differences at the earliest possible time to ensure that plaintiff has meaningful, continuous access to clients.
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