## Facts

- Inmates at the Nassau County Correctional Center (NCCC) brought a class action challenging unconstitutional conditions largely attributed to overcrowding.
- The parties entered a 1981 consent judgment setting a maximum NCCC population of 808 and requiring remedial measures.
- After continued noncompliance, a federal court order barred intake above 808; the overcrowding nevertheless persisted for an extended period, at times exceeding the facility’s rated capacity.
- The inmates moved to hold the Nassau County Sheriff and the NCCC Warden in civil contempt for violating the population cap in the amended consent judgment.
- The county officials argued they could not refuse prisoners committed by state courts and had made all reasonable efforts to comply; state correction officials were also parties to the litigation.
- The district court denied civil contempt, finding no willful violation and concluding compliance was “impossible” without state-level cooperation.
- The inmates appealed from the denial of civil contempt.

## Issues

1. Whether jail and correction officials subject to a federal consent judgment may avoid civil contempt by claiming “factual impossibility” based on political/administrative obstacles or asserted conflicts with state law.
2. Whether the officials proved they made good-faith, all reasonable efforts to comply with the population limit.

## Decision

- The court of appeals reversed the denial of the motion for civil contempt and remanded.
- It held that the officials could not rely on “factual impossibility” where the claimed barriers were not absolute, but instead reflected political and administrative difficulty and delay.
- It rejected the contention that state-court commitments required admission to NCCC in particular; the record showed allocation among facilities remained an executive responsibility.
- It directed enforcement of the amended consent judgment’s population controls, including coordinated action by county and state defendants to achieve compliance.

## Legal Principles

- Civil contempt may be excused only if the contemnor shows compliance was truly impossible despite good-faith, all reasonable efforts to comply.
- A party may not evade a binding federal consent judgment through unilateral noncompliance justified by political resistance, administrative inertia, or claimed tension with state law.
- If compliance with a federal decree is asserted to conflict with state law or to be unworkable, the proper course is to seek modification under applicable standards, not to disobey and later claim impossibility.
- Federal court orders control over contrary state-law considerations when enforcing constitutional remedies against state and local officials.

## Conclusion

The court required strict enforcement of the NCCC population-limit consent decree and held that officials could not avoid civil contempt by characterizing difficult implementation, state-law concerns, or intergovernmental coordination problems as “factual impossibility” absent proof of diligent, reasonable efforts to comply.


Badgley v. Santacroce, 800 F.2d 33 (2d Cir. 1986)