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Matter of Breeden v. New York State Dept. of Corr. & Community Supervision

Citation: 2020 NY Slip Op 469Docket: 529361

Court: Appellate Division of the Supreme Court of the State of New York; January 22, 2020; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

Darren Breeden initiated a CPLR article 78 proceeding against the New York State Department of Corrections and Community Supervision, contesting a tier II disciplinary determination that found him guilty of violating prison regulations. The case was reviewed by the Appellate Division, Third Department, on January 23, 2020. The Attorney General informed the Court that the disciplinary determination had been reversed, all related records expunged, and the $5 surcharge refunded to Breeden's inmate account. Consequently, since Breeden received full relief, the Court deemed the petition moot and dismissed it without costs. The decision was reached unanimously by Justices Egan Jr., Lynch, Mulvey, Aarons, and Reynolds Fitzgerald.

Legal Issues Addressed

Mootness Doctrine in CPLR Article 78 Proceedings

Application: The Court dismissed the petition as moot because the petitioner received full relief when the disciplinary determination was reversed, records were expunged, and the surcharge was refunded.

Reasoning: Consequently, since Breeden received full relief, the Court deemed the petition moot and dismissed it without costs.

Reversal of Disciplinary Determinations in Prison Context

Application: The reversal of the disciplinary determination included expunging all related records and refunding the surcharge, providing comprehensive redress to the petitioner.

Reasoning: The Attorney General informed the Court that the disciplinary determination had been reversed, all related records expunged, and the $5 surcharge refunded to Breeden's inmate account.