## Facts

- New York uses a bipartite corrections system in which some defendants sentenced to state prison are temporarily held in county jails before transfer to state custody.
- CPL 430.20(1) provides that when a sentence of imprisonment is pronounced, the defendant must “forthwith” be committed to the custody of the appropriate public servant.
- Due to state prison overcrowding, the Department of Correctional Services (DOCS) delayed accepting “state-ready” inmates from county jails, often for months.
- Forty-nine county sheriffs alleged DOCS’s delays caused county jail overcrowding and threatened inmate and staff health and safety.
- The sheriffs sought mandamus-style relief compelling DOCS to accept state-ready inmates within a short fixed period, restraining the Commission of Correction from enforcing certain jail standards when overcrowding resulted from the State’s delays, and compelling timely processing of alleged parole violators.
- The trial court ordered DOCS to accept state-ready inmates within 10 days after notice and limited certain enforcement actions tied to overcrowding.
- The Appellate Division modified, concluding courts could not impose a uniform time limit and that “forthwith” should be applied case by case.

## Issues

1. Whether CPL 430.20(1)’s requirement that a sentenced defendant be committed “forthwith” obligates the State to accept state-ready inmates from county jails without delay, notwithstanding state prison overcrowding.
2. Whether a court may enforce “forthwith” by imposing a uniform outer deadline (10 days) for DOCS to accept state-ready inmates after notice.
3. Whether county sheriffs have standing to challenge alleged delays in parole revocation proceedings.

## Decision

- The Court of Appeals held CPL 430.20(1) requires the State to accept, without delay, inmates committed to DOCS custody who are being held in local facilities.
- The court rejected DOCS’s position that it could delay acceptance based on comparative overcrowding or administrative balancing between state and local facilities.
- The court upheld the 10-day transfer requirement as a reasonable, enforceable implementation of the statutory command “forthwith,” recognizing only limited flexibility for logistics or exigent circumstances.
- The court held the sheriffs lacked standing to litigate the timeliness of parole revocation proceedings because those procedures protect parolees’ rights, not sheriffs’ institutional interests.

## Legal Principles

- Statutory terms signaling immediacy (such as “forthwith”) require prompt compliance and do not grant an agency open-ended discretion to delay performance for chronic capacity-management reasons.
- When the Legislature allocates custody responsibility to the State upon a state-prison sentence, the State may not shift that burden to counties through administrative delay.
- Courts may adopt a practical, uniform outer time limit to enforce an immediacy mandate in a systemic dispute, so long as the limit remains consistent with the statute’s requirement of prompt action.
- Standing requires that the claimant’s interests fall within the zone of interests the challenged procedures were designed to protect; third parties generally cannot assert rights-oriented procedural protections belonging to parolees.

## Conclusion

The Court of Appeals interpreted CPL 430.20(1) to require DOCS to accept state-ready inmates from county jails without delay and approved a 10-day deadline as a permissible means of enforcing “forthwith,” while dismissing the sheriffs’ parole-revocation timing claims for lack of standing.


Matter of Ayers v. Coughlin, 72 N.Y.2d 346, 530 N.E.2d 373 (N.Y. 1988)