Doe v. Coughlin

• Jurisdiction: North Carolina

Doe v. Coughlin

518 N.E.2d 536 (1987)

Facts

On June 6, 1985, John Doe, a New York State inmate serving a five-and-a-half- to eleven-year sentence at Auburn Correctional Facility married Jane Doe. The Does qualified for participation in the Auburn Prison Family Reunion Program and were allowed two-day conjugal visits in a trailer on prison grounds. In December, John Doe was diagnosed with AIDS, prompting correctional officials to deny the couple further conjugal visits. John Doe filed a lawsuit alleging that by denying him participation in the Family Reunion Program because of his AIDS status, New York State correctional officials violated his Fourth and Fourteenth Amendment rights. He contends that his fundamental rights to marital privacy, due process, and equal protection were violated. The New York Supreme Court dismissed his lawsuit ruling that the actions of correctional officials did not violate the U.S. Constitution, New York's constitution, or any New York state law. The case was appealed to the Second Circuit Court.

Issue

Whether New York correctional officials violated John Doe's Fourteenth Amendment rights to due process and equal protection by denying him continued participation in the Auburn Prison Family Reunion Program after he was diagnosed with AIDS.

Holding

The Second Circuit Court affirmed the decision of the New York Supreme Court, holding that in denying John Doe continued conjugal visits because he was diagnosed with AIDS, New York correctional officials did not violate his Fourth and Fourteenth Amendment rights or any of his rights under New York's constitution.

Reason

In making a ruling in this case, the Court of Appeals relied on previous decisions made by the court regarding its decisions that marital privacy rights can be retained by an inmate when they are not inconsistent with his status as a prisoner or when they do not conflict with the legitimate penological objectives of the correctional system. The appeals court dismissed Doe's claim that the Fourth Amendment entitled him to marital privacy and conjugal visits. The court reasoned that neither a prisoner nor his spouse has a constitutional right to marital relations as a condition of confinement. The state of New York has an obligation to make such arrangement for married inmates. The Appeals Court also disagreed with the assertion that since the correctional facility has established the Family Reunion Program, he has (because of his marital status) a constitutional...