New York Juvenile Detention Officials Sued for Abusing Adolescents with Solitary Confinement
by Chuck Sharman
Incarcerated in New York City’s notorious Rikers Island jail complex to await sentencing, 19-year-old Christopher M. recalled that he was not mistreated, with “regular access to daily schooling, religious services, organized recreational outlets, including a basketball team, unrestricted bathroom access, and liberal access to telephones,” according to a complaint later filed on his behalf. Importantly, he “was not subjected to solitary confinement.”
But in June 2025, he was placed at Goshen Secure Center, one of three secure lockups for juveniles and adolescents aged 12 to 21 operated by New York’s Office of Children and Family Services (OCFS). There, Christopher M. said that he was subjected to solitary confinement in cells without running water or toilets, leaving detainees to urinate and defecate “in plastic bottles, food containers, or garbage bins inside of their cells.” It was so bad and happened so frequently that he contemplated requesting transfer to an adult prison operated by the state Department of Corrections and Community Services (DOCCS).
To put that in perspective, it’s important to recall that DOCCS at the time was fresh off a wildcat guard strike bookended by fatal prisoner beat-downs at the hands of guards. However, the work stoppage secured a major objective for guards with an emergency order from Gov. Kathy Hochul (D) suspending parts of the Humane Alternatives to Long-Term (HALT) Solitary Confinement Act, as PLN reported. [See: PLN, Apr. 2025, p.9.] That the any youth detainee would opt for placement there speaks volumes about the conditions in OCFS detention.
When it took effect in March 2022, the HALT Solitary Confinement Act exempted OCFS facilities, where state law already prohibited isolating youthful detainees for punitive reasons, and never longer than 24 hours without top-level approval. The law was being ignored, Christopher M. said, and solitary confinement was used “as punishment for alleged rule infractions and, at times, minor misbehavior, including manifestations of youth’s disabilities.” Moreover, because OCFS failed to address chronic short staffing, detainees spent most weekends on lockdown, isolated in cells except for 30 minutes of daily recreation, also in isolation in an otherwise empty gym; even meals were taken alone.
With the aid of attorneys from the New York Legal Aid Society and Jenner & Block in Manhattan, Christopher M. and three fellow OCFS detainees—identified as Marcus F., Garrett M. and Isaac R.—filed their putative class-action lawsuit in January 2026 in the U.S. District Court for the Southern District of New York. Proceeding under 42 U.S.C. § 1983, they accused OCFS Director DaMia Harris-Madden and Norman Hall, Deputy Commissioner over the Division of Juvenile Justice and Opportunities for Youth, of violating youth detainees’ Eighth and Fourteenth Amendment rights with deliberate indifference to the serious risk of harm they face from these conditions. Since over 50% of OCFS detainees suffer from disabilities, the suit also lodged claims under the Americans with Disabilities Act, 42 U.S.C. ch.126 § 12101 et seq.
“If [parents] were doing the same things these facilities were doing to their children, they would have their children removed from their care by the same agency,” Legal Aid Society attorney Emma-Lee Clinger told the New York Focus.
Additionally, the Western New York Citizen Review Panel for Child Protective Services—one of three such panels providing oversight for the youth detention system—sent a letter to OCFS in April 2026, expressing alarm that “[c]hildren in state custody [are] deteriorating psychologically under the care of the very agency entrusted with their rehabilitation and safety.” The watchdog group demanded an “independent clinical review” of conditions in OCFS’s 11 facilities. Meanwhile, the district court partially granted Plaintiffs’ motion for a protective order to shield their identities on February 11, 2026. See: Marcus F. v. Harris-Madden, 2026 U.S. Dist. LEXIS 28800 (S.D.N.Y.).
Additional source: New York Focus
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Related legal case
Marcus F. v. Harris-Madden
| Year | 2026 |
|---|---|
| Cite | 2026 U.S. Dist. LEXIS 28800 (S.D.N.Y.) |
| Level | District Court |