U.S. District Court: RETALIATION.

• Position: Brief Article

Bowman v. City of Middletown, 91 F.Supp.2d 644 (S.D.N.Y. 2000). An arrestee who was held for 19 days on suspicion of murder brought a [sections] 1983 action alleging false arrest, malicious prosecution and civil rights violations while confined. The district court held that denial of commissary privileges for five days was not a due process violation, especially since the only deprivation suffered was the inability to order cigarettes, which was the sole item the detainee desired from the...