The U.S. Court of Appeals for the Second Circuit issued a summary order on Jan. 29, 2026, in *Disability Rights New York v. New York State Department of Corrections and Community Supervision*, addressing disability rights issues within the state's prison system.
The case, designated as No. 24-2563, involves Disability Rights New York as the plaintiff-appellant challenging the New York State Department of Corrections and Community Supervision and Commissioner Daniel F. Martuscello III in his official capacity. The three-judge panel consisted of Circuit Judges Reena Raggi, Susan L. Carney, and Beth Robinson.
Disability Rights New York, represented by attorney Christina Asbee along with Jonathan Greenwald and Brandy L.L. Tomlinson on the brief, brought the case against the state corrections agency. The organization, based in Albany, serves as an advocacy group focused on protecting the rights of individuals with disabilities throughout New York State.
The defendants were represented by Assistant Solicitor General Frederick A. Brodie, with Solicitor General Barbara D. Underwood and Senior Assistant Solicitor General Victor Paladino on the brief, appearing for Attorney General Letitia James.
The Second Circuit's ruling came in the form of a summary order, which the court explicitly notes does not have precedential effect. According to the court's standard language, citations to summary orders filed on or after Jan. 1, 2007, are permitted under Federal Rule of Appellate Procedure 32.1 and the court's Local Rule 32.1.1. When citing such orders, parties must reference either the Federal Appendix or an electronic database with the notation "SUMMARY ORDER" and serve copies on unrepresented parties.
While the complete text of the court's decision was not available in the source material, the case represents the latest development in ongoing litigation involving disability rights within New York's correctional system. The appeal suggests that a lower court ruling prompted Disability Rights New York to seek review from the federal appeals court.
The involvement of Disability Rights New York indicates the case likely concerns conditions, accommodations, or treatment of incarcerated individuals with disabilities within the state's prison facilities. The organization typically advocates for compliance with the Americans with Disabilities Act and other federal disability rights laws in institutional settings.
The New York State Department of Corrections and Community Supervision oversees approximately 50 correctional facilities throughout the state, housing tens of thousands of incarcerated individuals. The agency is responsible for ensuring compliance with federal disability rights laws, including providing reasonable accommodations and accessible facilities for inmates with disabilities.
Commissioner Martuscello's inclusion as a defendant in his official capacity suggests the case may involve systemic policies or practices rather than individual incidents. Such litigation typically seeks injunctive relief requiring changes to agency-wide procedures or facility conditions.
The Second Circuit's jurisdiction encompasses New York, Connecticut, and Vermont, making it the primary federal appellate court for disability rights cases involving state agencies in these jurisdictions. The court regularly addresses issues involving institutional conditions and disability accommodations in correctional, educational, and healthcare settings.
Summary orders represent a streamlined approach to appellate decisions, typically used when the legal issues are well-established or when the court's analysis does not warrant a full precedential opinion. While these orders resolve the specific dispute between the parties, they do not establish binding precedent for future cases.
The timing of the decision, coming in late January 2026, suggests the appeal was filed sometime in 2024, based on the case number designation. The appellate process in the Second Circuit typically takes several months to over a year, depending on the complexity of the issues and the court's docket.
For disability rights advocates, the case represents part of ongoing efforts to ensure that correctional facilities comply with federal disability laws. Prison systems nationwide face regular litigation over accessibility issues, medical care, mental health services, and reasonable accommodations for incarcerated individuals with disabilities.
The outcome of this appeal, while not creating precedent due to its summary order format, may influence how New York's corrections department addresses disability-related issues within its facilities. The case also reflects broader national discussions about the treatment of vulnerable populations within correctional settings.
Going forward, the parties will need to implement any directives from the Second Circuit's order. If the court remanded the case, further proceedings may occur in the district court. If the court affirmed or reversed a lower court ruling, the decision would resolve the immediate legal dispute while leaving room for future challenges involving similar issues.
The case highlights the ongoing intersection between disability rights law and correctional administration, an area that continues to generate litigation as advocacy groups work to ensure equal treatment and access for individuals with disabilities in institutional settings.