Serrano v. Coughlin, 74 N.Y.2d 639 (1989)

In prison disciplinary proceedings, written reports alleging inmate misconduct must contain specific details about the individual’s actions to constitute substantial evidence of guilt; generalized reports that all inmates present participated in a disturbance are insufficient.

Summary

Two inmates, Serrano and Bryant, were charged with violating a prison disciplinary rule for participating in a riot. The primary evidence consisted of written reports stating that all inmates in the mess hall were actively participating in the riot. The New York Court of Appeals held that these generalized reports, lacking specific details about each inmate’s conduct, did not constitute substantial evidence to support the disciplinary determinations. The Court emphasized that prison disciplinary determinations must be supported by substantial evidence, and the Commissioner must adhere to their own regulations requiring specificity in misconduct reports.

Facts

During dinner at Great Meadow Correctional Facility, a riot erupted in the north mess hall, involving approximately 130-140 inmates. Correction officers reported assaults and the use of weapons by inmates. Petitioners Serrano and Bryant, present in the mess hall, were subsequently charged with violating prison disciplinary rule 104.10, which prohibits inmates from engaging in violent group conduct. The evidence against them primarily consisted of written reports stating that all inmates present were actively participating in the riot. Serrano was also accused based on information from a confidential informant who claimed Serrano was throwing trays.

Procedural History

Both inmates were found guilty at their respective disciplinary hearings. Serrano’s penalty included 365 days’ confinement, loss of privileges, and loss of good time. Bryant’s penalty was similar but later modified on administrative appeal. After exhausting administrative remedies, both inmates filed Article 78 petitions challenging the determinations as unsupported by substantial evidence. The Appellate Division confirmed the findings, but the Court of Appeals reversed, holding that the evidence was insufficient.

Issue(s)

1. Whether written reports stating that all inmates present at a riot participated in violent conduct, without specifying individual actions, constitute substantial evidence to support a disciplinary determination against specific inmates.

2. Whether information from a confidential inmate informant, without further corroboration, is sufficient to support a disciplinary determination.

Holding

1. No, because the reports lacked specific details about the individual inmates’ actions, failing to meet the requirements of the Department of Correctional Services regulations.

2. The Court did not reach this issue as it found the other evidence insufficient; however, the Appellate Division had previously deemed such uncorroborated third-party information insufficient.

Court’s Reasoning

The Court emphasized that a prison disciplinary determination must be supported by substantial evidence, and the Commissioner must follow their own regulations. The regulations require that reports of inmate misbehavior should indicate the specific role played by each inmate involved. The Court found that the reports offered as evidence against Serrano and Bryant failed to meet this requirement, as they only contained conclusory statements that all inmates present in the mess hall participated in the disturbance, without any reference to the specific actions of Serrano or Bryant. The Court stated that “[e]ach of these reports contains only conclusory statements that all inmates present in the mess hall participated in the disturbance, with no reference to either petitioner.” The Court rejected the argument that any degree of participation in a riot justifies a finding of guilt, stating that the reports did not particularize any degree of involvement by either petitioner. Regarding the confidential informant’s information against Serrano, the Court declined to address whether its admission was harmless error, as it found the other reports insufficient. The Court highlighted that “[i]n the cases before us, the failure of the Commissioner to follow his own regulations in the reports by specifying an inmate’s misconduct must be considered a material defect.” The court distinguished the case from People ex rel. Vega v. Smith, stating the reports here fell “well below the particularized individual descriptions of misconduct held sufficient in Vega“.