Letter to Deputy Commissioner Sheehan on the DOCCS failure to implement HALT regulations

The NYCLU wrote to Deputy Commissioner Sheehan to express serious concern over the New York State Department of Corrections and Community Supervision’s (“DOCCS”) ongoing failure, in violation of state law, to assess public comments on DOCCS rules implementing the Humane Alternatives to Long-Term Solitary Confinement Act (“HALT”) in state prisons. Over a year since HALT became law, DOCCS has declined to finalize permanent rules implementing the Act. Instead, after its initial combined emergency/proposed rulemaking in April 2022, DOCCS has bypassed the standard rulemaking process, implementing its HALT rules by repeatedly and successively invoking emergency rulemaking.