Detained in Law, Degraded in Practice: the Underworld of Abuse in New York State Prisons

As of February 2025, several prison officials are to be charged in the murder case of Robert Brooks, an inmate an Upstate New York correctional facility, who was fatally beaten on December 9th of the previous year. Despite the particular media attention paid to this incident and itstrial, Brooks’ case is simply one of the many in which inmates experience physical abuse in correctional facilities. It is rather indicative of a larger pattern of inmate mistreatment in the New York State correctional system. This phenomenon brings to light how present state law fails to adequately protect incarcerated individuals from abuse by prison officials. Overall, these instances of violence against inmates amount to evident violations of the Eighth Amendment’s protections against cruel and unusual punishment. Brook’s case together with many others highlights the vacuum in prisoners’ rights, revealing where federal and state law fail to prevent correctional officials from exploiting their power and victimizing incarcerated individuals.

In December of 2024, Robert Brook’s assault came into the public eye via the disturbing body camera footage of his murder. The very day of the assault, prison officials transported Brooks to Marcy Correctional Facility from a nearby prison where he had been attacked by at least two other inmates. During the incident, four officers carried Brooks into an infirmary and began to use physical force on him after Brooks allegedly attempted to bite one of them. While the officers failed to activate their body cameras during the assault, a feature of the technology that continues recording even after turned off allowed for multiple angles of footage. In these videos, several officers are seen striking and kicking Brooks repeatedly while he was handcuffed against an examination bed. Brooks died of the injuries sustained during this assault the following morning. Though Brooks presented with numerous other physical injuries, the county medical examiner’s preliminary autopsy found that asphyxia was likely the ultimate cause of death and later ruled his death a homicide. In addition to the officers who perpetrated the assault, the indictment implicated several other witnesses who failed to intervene. 

Despite the jarring body camera footage and brutality of Brooks’ assault, his case is not an isolated incident and likely represents a larger phenomenon of inmate abuse throughout state prisons. Since these correction officers had deactivated their body cameras during the assault, violating the department’s policy, it can be inferred that occurrences such as this could be happening more frequently than imagined. In fact, Marcy Correctional Facility confirmed to local news sources that many cases of assault go unrecorded. This consistent, excessive, and evidently fatal force on inmates is grounds for concern. Various other documented cases of physical assault in New York State prisons exemplify the pervasiveness of these incidents. 

Around the same time as Robert Brooks’ murder, a ruling came down on a lawsuit involving another instance of violence perpetrated on inmates by correctional officers in Marcy, NY at the Mid-State Correctional Facility. After a false claim that an inmate had attacked one of the officers, thirty corrections officials entered a dormitory full of inmates and conducted what was virtually a rampage, brutally assaulting multiple inmates physically, sexually, and verbally. Some inmates even testified that officers used racial slurs toward them during the raid. In the indictment, the judge presiding over this case found the State of New York liable for “all assaults and batteries committed” against the inmates. The judge’s decision also notes how this raid was an attempt at intimidation by the correctional officers who sought to scare inmates in Mid-State into submission. He cites the immense fear that inmates expressed during the assault as well as correctional officers’ remarks asking inmates how it felt “to be scared…and be helpless.” This further displays the dehumanizing nature of the raid, highlighting a clear exploitation of power by correctional officers. Though the death of Robert Brooks took center stage in the news due to the shocking body camera footage, this case serves as another example of the highly frequent abuse of prisoners in state facilities.

The psychological, verbal, and physical abuse described in the court documents characterize the particularly heinous and dehumanizing nature of the Mid-State correctional officer raid. The Eighth Amendment’s cruel and unusual punishment protections extend to include the use of excessive force by prison officials, or malicious acts with the intent to cause harm. Though it should in theory protect inmates from abuse by prison officials and other inmates, it is evident that in practice it fails to do so. This use of excessive force is undeniably outside of the bounds of the sentencing for the incarcerated individuals affected. Therefore, both Brooks’ murder and the Mid-State raid constitute violations of these inmates’ constitutional rights. Moreover, the abuse that Brooks faced by other inmates at a previous prison further emphasizes how facilities regularly deprive incarcerated individuals of due safety and protections. Unfortunately, though the State of New York was held liable for the abuses in the Mid-State facility, we still await the result of Brooks’ murder trial. Further cause for concern is that an indeterminable amount of inmates face mistreatment and will not receive justice due to the frequency of body camera violations or even state cover ups. Out of 298 cases of inmate physical abuse perpetrated by correctional officers since 2010, only twenty-eight cases ended with an officer being ousted. This exemplifies the concerning rate at which the rights violations of incarcerated individuals go unaddressed. 

Once individuals become incarcerated, it appears as if some of their most fundamental rights go consistently unacknowledged. Correctional officers in state prisons often use excessive force in the form of performative punishment. Robert Brooks’ case not only proves that instances of inmate abuse can often be fatal, but that officers routinely make concerted efforts to hide these events—causing them to often go undetected. These exploitations of power by correction officers call into question whether incarcerated people have adequate legal protections from violence while behind bars. Besides the federal law, there currently exists a vacuum in NYS law specifically protecting inmates from abuse in state facilities. Though a 2023 State Senate bill sought to enshrine more rights for incarcerated people, it died in committee. In truth, fell short of protecting inmates from the pervasive violence by prison officials. The introduction of new state laws that include officer de-escalation training, limits on the use of restraints on inmates, and stricter enforcement of body camera footage may aid in reducing these assaults. As the outcome of Robert Brooks’ case still looms in the distance, only concrete changes to current legislation will prevent the victimization of more incarcerated individuals at the hands of state authorities.

Sinclair Harris is a sophomore concentrating in International and Public Affairs and History at Brown University. She is a writer for the Brown Undergraduate Law Review and can be reached at sinclair_harris@brown.edu.

Ashley Park is a first-year concentrating in International and Public Affairs and Political Science at Brown University. She is an editor for the Brown Undergraduate Law Review and can be reached at ashley_h_park@brown.edu.