Urena v. The City of New York

Background

Amaury Urena filed the action without a lawyer and had permission to proceed without paying filing fees upfront. He sought damages, an order requiring defendants to stop allegedly cruel and inhumane treatment of detainees awaiting trial, and appointment of counsel. He sued the City of New York, the U.S. Department of Justice, the “Deputy Warden of Bronx Court,” and two unidentified defendants.

Urena alleged that on various dates from approximately March 17, 2021, through February 27, 2023, and afterward, he was searched before being transported to what appeared to be the Criminal Part of the New York Supreme Court, Bronx County. He alleged that he was searched again after arriving, then held in a state-court holding cell while awaiting proceedings. He said he was handcuffed and shackled with waist chains and “mittens,” alone in a cell, and unable to eat or use the bathroom humanely and regularly. He claimed violations of the Fourteenth and Eighth Amendments and alleged back, wrist, and ankle pain, mental anguish, and emotional distress.

Screening standards

Because Urena was a prisoner seeking relief from governmental defendants, the court screened the complaint under the Prison Litigation Reform Act. The court was required to dismiss claims that were frivolous, malicious, inadequately pleaded, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. Although courts read self-represented complaints liberally, Rule 8 still requires enough factual detail to make a claim plausible rather than merely possible.

Claims on behalf of other prisoners

The court dismissed, without prejudice, Urena’s claims concerning other prisoners. A person representing himself may litigate only his own personal interests, and the opinion states that Urena did not allege that he was a lawyer.

Claims against the Department of Justice

The court dismissed Urena’s claims against the Department of Justice under sovereign immunity, the rule that generally prevents suits against the federal government and its agencies unless immunity has been waived. The court found that Urena alleged nothing showing a waiver. It therefore also dismissed those claims for lack of subject-matter jurisdiction.

Claims against the City of New York

The court dismissed Urena’s claims under 42 U.S.C. § 1983 against the City for failure to state a claim. A municipality is not liable under that statute merely because one of its employees allegedly did something wrong. Urena needed to allege facts showing that a City policy, custom, or practice caused the violation of his federal rights. The court found that he had not done so.

The court granted Urena leave to replead his claims against the City by alleging facts showing that a City policy, custom, or practice caused the alleged constitutional violation.

Claims against individual defendants

The court dismissed Urena’s § 1983 claims against the individual defendants for failure to state a claim. A person sued under § 1983 must have been directly and personally involved in the alleged constitutional violation; supervisory responsibility alone is not enough. The court found that Urena had not explained how any individual defendant was directly and personally involved.

The court granted leave to amend so Urena could identify individual state actors who were directly and personally involved and explain what each person allegedly did.

Conditions-of-confinement claims

The court treated the complaint as asserting § 1983 claims based on the conditions in the state-court holding cell. The opinion states that the legal standard depends on whether Urena was a pretrial detainee or a convicted prisoner: a pretrial detainee’s claim arises under the Fourteenth Amendment, while a convicted prisoner’s claim arises under the Eighth Amendment.

Under either framework, Urena had to allege that the conditions posed an unreasonable risk of serious harm. He also had to allege the required mental state of the responsible official. For a convicted prisoner, that generally requires knowledge of and disregard for an excessive risk. For a pretrial detainee, it requires intentional imposition of the condition or reckless failure to take reasonable care despite knowledge, or reason to know, of an excessive risk.

The court found that Urena did not identify whether he was a pretrial detainee or convicted prisoner during the relevant events. It further found that he had not alleged facts showing that any correctional or custodial defendant had the required deliberate disregard or comparable mental state. The court therefore dismissed the conditions-of-confinement claims for failure to state a claim, while granting leave to replead them.

Leave to amend and disposition

The court granted Urena 60 days to file an amended complaint. The amended complaint must replace the original complaint rather than supplement it. It must identify each defendant in the caption and explain the relevant facts, including what each defendant did or failed to do, when and where the events occurred, the injuries suffered, and the relief sought. If a defendant’s name is unknown, Urena may use “John Doe” or “Jane Doe” with descriptive information, but the opinion states that using a Doe name does not stop the limitations period from running.

The court stated that failure to comply, absent good cause, would result in dismissal of the action, including dismissal of the claims brought for others without prejudice, the claims against the Department of Justice for lack of jurisdiction, the § 1983 claims for failure to state a claim, and the request for appointment of counsel as moot. The court did not issue summonses at that time and certified that an appeal would not be taken in good faith, denying fee-free status for an appeal. Judge Laura Taylor Swain signed the order.