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NY Prison Disciplinary Hearing that Doesn’t Consider Insane Prisoner’s Mental Health Held Invalid

Leon Reed, a New York state prisoner, stabbed another prisoner to death in September of 1976 at the Gaveen Haven Correctional Facility. He was found not guilty of murder in state court by reason of insanity. Even so, he was found guilty at a subsequent prison disciplinary hearing where his sanction included seven years loss of good time, seven years in segregation, and other privilege deprivations. Reed challenged the disciplinary action in state court.

On review, the Supreme Court (trial court) of New York, Oneida County recognized that the hearing officer at Green Haven didn’t take into account the fact that Reed had been found not guilty of the murder because of his mental condition in court. The Court then reversed the disciplinary action, holding the same to be unsupported by adequate evidence because evidence of Reed’s mental condition was not considered. See: NY ex rel. Reed v. Scully, 140 Misc, 2d 379, 531 N.Y.S. 2d 196 (1988).

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Related legal case

NY ex rel. Reed v. Scully