Satchell v. Molina

Background

John Satchell, proceeding without a lawyer, sued Louis Molina, identified as the former Commissioner of the New York City Department of Correction, and Ms. Ford, identified as the former Warden of the Vernon C. Bain Center. Satchell alleged that his constitutional rights were violated during his detention in Department of Correction custody and in connection with his ongoing state criminal proceeding. He stated that he had been in custody since 2019, had not received bail, had lost his job, car, and residence, contracted COVID-19, was repeatedly strip searched, and was “put in harms way.” He did not specify the relief he wanted.

The court had previously allowed Satchell to proceed without paying court fees in advance. It screened his complaint under the federal prisoner-screening statutes, which require dismissal of claims that are frivolous, malicious, fail to state a claim, seek money from an immune defendant, or fall outside the court’s jurisdiction.

Rulings

Ongoing state criminal proceeding

To the extent Satchell sought federal-court intervention in his pending state criminal case, the court applied the rule from Younger v. Harris. That rule generally prevents a federal court from stopping a parallel state criminal proceeding unless the plaintiff alleges bad faith, harassment, or a serious and immediate risk of irreparable injury. Because Satchell alleged no facts supporting those exceptions, the court abstained from intervening and dismissed any claims for injunctive relief concerning the state proceeding.

Strip-search allegations

The court explained that a claim challenging strip searches would arise under the Fourth Amendment. Such searches must be reasonable and related to a legitimate prison or jail purpose. Satchell did not allege why he was searched, how the searches were conducted, facts showing an intent to humiliate or abuse him, or the identities of the correctional officers who conducted the searches. The court therefore found that he had not stated a viable claim but granted him leave to amend with additional facts.

Conditions of confinement

Because Satchell was a pretrial detainee, his conditions-of-confinement claims would arise under the Fourteenth Amendment. He needed to allege both that the conditions posed an objectively unreasonable risk to his health or safety and that an official intentionally imposed the condition or recklessly failed to take reasonable measures despite knowing, or having reason to know, of an excessive risk.

The court found that Satchell’s general statements about contracting COVID-19 and being put in harm’s way did not show an objectively serious risk or deliberate indifference by any official. It nevertheless granted leave to amend so he could provide specific facts about the alleged risks, the officials involved, and how those officials acted or failed to act. The court also noted that Satchell could not pursue the same claims in two separate lawsuits.

Claims against Molina, Ford, and the City of New York

A claim under 42 U.S.C. § 1983 requires facts showing that each defendant was personally involved in violating the plaintiff’s constitutional rights. A supervisor cannot be held liable merely because someone who violated the plaintiff’s rights worked under that supervisor.

The court dismissed Satchell’s claims against former Commissioner Louis Molina and former Warden Ford because he did not allege how either official was personally involved in the events or specifically violated his rights. To the extent Satchell intended to sue them in their official capacities, the court treated those claims as potentially directed against the City of New York and directed the Clerk of Court to add the City as a defendant.

A municipal-liability claim requires facts showing that a City policy, custom, or practice caused a constitutional violation. The court found that Satchell had not alleged facts showing that a City policy, practice, or custom caused the alleged violations at the Vernon C. Bain Center or on Rikers Island. The court granted him leave to plead such a claim in an amended complaint.

State-law claims and amendment

The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims because Satchell was being allowed to amend and the federal claims had not yet been finally resolved.

Judge Laura Taylor Swain granted Satchell 60 days from the date of the order to file an amended complaint. The amended complaint must replace the original complaint, include all facts and claims Satchell wants the court to consider, identify the people personally involved, describe the relevant events and injuries, and state the relief sought. If he did not know a defendant’s name, he could use a John Doe or Jane Doe designation, but the court stated that doing so would not pause the three-year limitations period for his § 1983 claims. No summons would issue at that time.

The order states that if Satchell failed to comply within the allowed period without good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying appellate fees for purposes of an appeal.