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Matter of Prisoners’ Legal Services of New York v. New York State Department of Correctional Services – Case Brief Summary (New York)

In Matter of Prisoners' Legal Services of New York v. New York State Department of Correctional Services, 73 NY2d 26, 535 N.E.2d 243, 538 NYS2d 190 [1989], the Court agreed with the Appellate Division's reasoning that the legislative purpose of protecting police and correction officers from harassment and reprisals would be served by granting the statutory protection of Civil Rights Law §50-a before, as well as after, commencement of an action.

The court continued that records pertaining to inmate grievances would fall within the statute as they are documents containing personal, employment-related information about a public employee which are received, processed and maintained as part of a correctional facility's, and that they are clearly relied upon in evaluating the employee's performance.

It continued that whether a document qualifies as a personnel record under Civil Rights Law § 50-a (1) depends upon its nature and its use in evaluating an officer's performance, not its physical location or its particular custodian.