Jaime v. New York State Department of Corrections Community Supervision

Background

Luis Jaime, who was incarcerated at Wende Correctional Facility when he filed the complaint, proceeded without a lawyer. He sued the New York State Department of Corrections and Community Supervision (DOCCS), Sullivan Correctional Facility, Doctor Guzman, Nurse Konkol, and Nurse Practitioner Armbruster. The court understood the claims against the three medical employees to be brought both in their official capacities as DOCCS employees and in their individual capacities.

Jaime asserted claims under 42 U.S.C. § 1983, a law that allows claims for violations of federal rights by people acting under state authority, as well as state-law claims. He sought damages and prospective injunctive relief—court orders requiring future conduct. His requested orders included directing doctors and nurses at Sullivan to document and treat injuries humanely. The court had already granted him permission to proceed without prepaying filing fees, but it screened his complaint under the federal prisoner-screening laws.

Claims Dismissed Under State Immunity

The court dismissed Jaime’s Section 1983 claims against DOCCS and his claims for damages under Section 1983 against the Individual Defendants in their official capacities. It also dismissed his state-law claims against DOCCS and the Individual Defendants.

The court relied primarily on Eleventh Amendment immunity, which generally protects states, state agencies, and state officials sued in their official capacities from suits in federal court. It concluded that DOCCS is an arm of New York State. The court stated that New York had not waived its immunity for these claims and that Congress had not removed that immunity for Section 1983 claims. The court further stated that state-law claims against DOCCS or state employees acting in their official capacities could be heard only in the New York Court of Claims. The opinion also explains that New York Correction Law § 24 bars certain state-law damages claims against DOCCS employees for conduct within the scope of their employment from being considered in this court.

Claims Against Sullivan Correctional Facility

The court dismissed Jaime’s Section 1983 claims against Sullivan Correctional Facility for failure to state a claim on which relief may be granted. Section 1983 requires a plaintiff to allege a violation of a federal right by a person acting under state authority. The court held that a prison facility is not a “person” subject to suit under Section 1983.

Requests for Injunctive Relief

The court dismissed as moot Jaime’s Section 1983 claims for prospective injunctive relief brought on his own behalf. Because he had been transferred from Sullivan to Wende before filing the complaint, the court concluded that orders directed at conditions at Sullivan would no longer provide him relief.

The court separately dismissed without prejudice any claims for prospective injunctive relief that Jaime asserted on behalf of other Sullivan prisoners. The court explained that a nonlawyer may represent only himself in federal court and may not bring claims for another person. “Without prejudice” means those claims were not barred from being brought again by a proper representative or in a proper case.

Claims Allowed to Proceed and Service

The court allowed Jaime’s remaining claims for damages under Section 1983 against Guzman, Konkol, and Armbruster in their individual capacities to proceed. The court did not resolve the underlying merits of those remaining claims in this screening order.

Because Jaime was proceeding without prepaying filing fees, the court directed the clerk to issue summonses and prepare the required service forms for Guzman, Konkol, and Armbruster. It directed the U.S. Marshals Service to handle service. The court stated that Jaime should request more time if service was not completed within 90 days after the summonses were issued, and that he must notify the court in writing if his address changes.

Disposition

The court dismissed the specified claims against DOCCS, Sullivan, and the Individual Defendants, including the claims dismissed under Eleventh Amendment immunity, the claims dismissed as moot, and the claims dismissed for failure to state a claim. It dismissed without prejudice the claims Jaime asserted on behalf of other Sullivan prisoners. His Section 1983 damages claims against the Individual Defendants in their individual capacities may proceed.

Judge Kenneth M. Karas also certified that an appeal from the order would not be taken in good faith and denied Jaime permission to proceed without prepaying fees for an appeal.