## Facts

- Twelve married women alleging domestic abuse sought declaratory and injunctive relief against nonjudicial personnel of the New York City Family Court and officials of the New York City Department of Probation.
- Plaintiffs alleged a pattern of conduct by clerks and probation staff, with supervisory knowledge or approval, intended to:
  - deter battered wives from filing petitions for orders of protection,
  - block meaningful access to Family Court judges empowered to issue temporary orders of protection, and
  - steer complainants into counseling/mediation by failing to disclose that counseling was voluntary.
- The statutory framework provided for orders of protection that could restrain an offending spouse and be enforced through contempt sanctions, including possible imprisonment.
- Plaintiffs alleged that pro se litigants depended on court personnel for procedural guidance, making staff conduct practically determinative of access to judicial remedies.
- During the litigation, agencies adopted policy changes and directives aimed at preventing discouragement of filings and informing complainants of their ability to proceed to court rather than mediation.

## Issues

1. Whether claims that Family Court clerks and probation officials systematically impeded access to statutory orders of protection presented a justiciable controversy suitable for declaratory and injunctive relief.
2. Whether, given administrative reforms and official assurances made during the litigation, any remaining dispute warranted a trial or court-ordered, continuing supervision of agency practices.

## Decision

- The Court of Appeals affirmed dismissal of the complaint.
- The court concluded that a trial would serve no useful purpose in light of policy changes and sworn commitments to comply with governing law and court rules.
- The court declined to impose broad, continuing injunctive relief that would require day-to-day judicial oversight of Family Court and probation administration.
- The opinion recognized the importance of access to Family Court remedies but treated implementation and monitoring of internal practices as primarily an administrative matter once reforms were adopted.

## Legal Principles

- Courts may deny structural injunctive relief where the requested remedy would entail ongoing judicial management of internal operations of courts or related agencies rather than resolution of discrete legal violations.
- Where defendants adopt corrective policies and provide binding representations of compliance during litigation, a court may dismiss and forgo trial if further proceedings would not materially advance effective relief.
- Statutory rights to seek protective orders are judicially cognizable, but the form of relief must be judicially manageable and consistent with limits on supervisory control over administrative functions.

## Conclusion

The court affirmed dismissal because the relief sought would have required continuing judicial supervision of Family Court and probation operations, and intervening administrative reforms and official commitments made further litigation and an evidentiary trial unnecessary.


Bruno v. Codd, 47 N.Y.2d 582 (N.Y. 1979)