The Second Circuit has revived a suit by a man held on Rikers Island for over seven years who alleged that inadequate procedures by the agency that runs New York City's jail kept him incarcerated for an extra 17 days.

The three-judge panel held on Tuesday that James Seabrook – whose 7.5 year detention was one of the longest in Rikers history — sufficiently alleged that the New York City Department of Correction and its administrators refused to expedite his release from custody.

"At this early stage of litigation, further record development is needed to understand what procedures were available to Seabrook beyond the ad hoc and largely ineffective communications with DOC that are alleged in the complaint," U.S. Circuit Judge Beth Robinson said in the opinion. "But on the pleadings, Seabrook has alleged that there is no process within DOC's control that would have minimized the risk of this serious deprivation of liberty or would have shortened the duration of the deprivation."

Seabrook was arrested in May 2016 and charged with six crimes, including third-degree criminal possession of a weapon. Seabrook was detained pretrial and in April 2019 a jury convicted him of the weapon possession charge but was hung on the more serious charged offense, the opinion said.

Seabrook was tried two more times before a jury in December 2023 acquitted him of the remaining charges, the opinion said. Local New York City media reported in August 2023 that Seabrook's over seven years on Rikers Island made him one of the top five longest-held detainees on the island.

A state trial court sentenced Seabrook on the weapon possession charge in January 2024 to between 3.5 and 7 years in prison. Prosecutors and Seabrook both agreed at sentencing that he had already been held at Rikers longer than the maximum length of his sentence, the opinion said.

The state court ordered that Seabrook be moved from DOC custody into the custody of the state prison system, run by the Department of Corrections and Community Supervision, or DOCCS. Seabrook was taken from sentencing and returned to Rikers Island so he could be transferred to DOCCS and then be released, the opinion said.

Once Seabrook was back in DOC custody on Rikers Island, his attorney notified the jail that he was being held in excess of his sentence. A week later, Seabrook's attorney was told by DOC's general counsel that Seabrook was awaiting transfer to an upstate facility to have his sentence calculated by DOCCS, the opinion said.

DOC maintained that the agency could not seek Seabrook's immediate release while he was at Rikers and he instead needed to be physically transferred to a DOCCS facility upstate. Seabrook's attorney again contacted DOC a week later, and the Rikers Island warden said his staff were trying to "expedite" Seabrook's transfer to DOCCS custody, the opinion said.

DOC Capt. Anthony Monastero, who runs the jail's Custody Management Unit, said DOC was not allowed to either release or transfer him upstate without DOCCS authorization. The same day Monastero emailed Seabrook's attorney, Seabrook was released without being transferred to DOCCS, the opinion said.

Seabrook filed a lawsuit alleging the 17-day detention violated his Fourth, Eighth and 14th Amendment rights. The city and its employees named in the lawsuit sought dismissal, with the employees seeking qualified immunity, the opinion said.

A district court granted the request in full, finding that Seabrook's lawsuit did not adequately provide specifics about how a city policy led to his over-detention on Rikers. Seabrook appealed, arguing the city's policy of requiring incarcerated people be physically transferred to DOCCS led to unconstitutional over-detention, the opinion said.

The Second Circuit agreed, finding that the jail was not required under state law to physically transfer incarcerated people to DOCCS. The state's "bipartite" corrections system means an incarcerated person could remain in physical custody at Rikers, while being in the legal custody of DOCCS, the opinion said.

The Second Circuit also found that Seabrook's complaint plausibly alleged Monastero acted with deliberate indifference by not seeking his expedited release. The court said the allegations supported an inference that Monastero, despite knowing of the over-detention, failed to act sooner.

The Second Circuit held that while both the city and its officials could prove it tried to expedite Seabrook's release, it would need to do so in discovery. Seabrook's lawsuit sufficiently alleged that a series of policy choices by DOC and its staff led to his over-detention, the opinion said.

A spokesperson for the New York Law Department that represents the agency and its employees said it plans to show that they are not liable in Seabrook's case.

"We stand firmly behind the arguments we made, which we believe will be reinforced as we proceed with discovery," the spokesperson said.

Alice Reiter, a Wang Hecker LLP attorney who represents Seabrook, told Law360 in an email that the city's lack of a policy was at the heart of this lawsuit.

"This decision is a crucial step toward ending this unconstitutional practice," Reiter said. "No one should spend an extra day in jail — let alone weeks — because the city has failed to establish procedures to ensure their timely release."

U.S. Circuit Judges Eunice C. Lee and Beth Robinson and U.S. District Judge Eric R. Komitee sat on the panel for the Second Circuit.

Seabrook is represented by Alice G. Reiter and Eric J. Hecker of Wang Hecker LLP.

The government is represented by Jamison Davies, Richard Dearing and Jeremy W. Shweder of the New York City Law Department.

The case is James Seabrook v. City of New York et al., case number 25-2095 in the U.S. Court of Appeals for the Second Circuit.

--Editing by Linda Voorhis.