Vincent v. Annucci, No. 21-22 (2d Cir. 2023)
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Plaintiff brought a 42 U.S.C. Section 1983, seeking compensatory damages for the 686 days that he was unlawfully incarcerated after the Second Circuit clearly established in Earley v. Murray that only a court could lawfully impose post-release supervision (PRS). Plaintiff served this time for violating the terms of his PRS that the New York Department of Correctional Services (DOCS)—not his sentencing judge—had imposed. He sued various New York state officials, including Defendant, then-Deputy Commissioner and legal counsel for DOCS, for the unlawful deprivation of his liberty under the Due Process Clause of the 14th Amendment of the Constitution. On appeal, Defendant challenged the district court’s award of compensatory damages to Plaintiff and revives his claim of qualified immunity, which was previously unsuccessful.
The Second Circuit affirmed in part and vacated in part the district court’s decision. The court explained that it previously held in Vincent v. Yelich, 718 F.3d 157 (2d Cir. 2013) that the unconstitutionality of administratively imposed terms of PRS was clearly established by Earley I. And the court later held in Betances v. Fischer, 837 F.3d 162 (2d Cir. 2016) that because Defendant failed to make objectively reasonable efforts to comply with federal law that was clearly established by Earley I, he was not entitled to qualified immunity. Defendant offers no compelling argument for the court to reconsider these prior holdings. The court thus concluded that the district court did not err in applying the court’s prior precedents to deny him qualified immunity.
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