Muflihi v. Rikers Island Employees
- Valerie Caproni
- 1:24-cv-00395
- U.S. District Court · Southern District of New York
- 9
In Muflihi v. City of New York, Judge Caproni requested service waiver and ordered identification of unnamed defendants in a religious-practice lawsuit.
Salman Muflihi, the City of New York, the unnamed Department of Correction sergeants and correctional officers, and the unnamed religious-services defendants identified in the complaint.
What happened
In Salman Muflihi v. The City of New York, et al., Salman Muflihi, representing himself, sued under a federal civil-rights law. He alleges that defendants interfered with his religious practice during Ramadan in 2021 and 2022 while he was a pretrial detainee at Rikers Island.
The court requested that the City of New York waive formal delivery of the summons. It also ordered the New York City Law Department to identify the unnamed sergeants, correctional officers, imam, and Muslim chaplain or director named in the complaint, including their badge numbers and service addresses. After receiving that information, Muflihi must file a second amended complaint naming those defendants.
Judge Valerie Caproni issued an order directing these service and identification steps. The order did not decide whether Muflihi’s allegations were legally valid.
The detailed version
- Muflihi v. Rikers Island Employees · No. 1:24-cv-00395
- Valerie Caproni
- June 28, 2024
Background
Salman Muflihi paid the filing fees and filed this case without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims against state or local actors for violating constitutional rights. The opinion states that he is currently incarcerated at Attica Correctional Facility. He alleges that, while he was a pretrial detainee at Rikers Island, defendants impeded his religious practice during Ramadan in 2021 and 2022.
The named defendants are the City of New York; unnamed sergeants on duty at the Anna M. Kross Center; unnamed correctional officers on duty there; an “Islamic Affairs Coordinator – Imam”; and a Muslim Chaplain or the Director of Ministerial, Family and Volunteer Services.
Court’s Actions
The court directed the Clerk of Court to notify the New York City Department of Correction and the New York City Law Department of the order. The court requested that the City of New York waive service of a summons, meaning that the City could accept the lawsuit papers without personal delivery by a process server.
Under a procedure requiring court assistance in identifying unknown defendants, the court found that Muflihi had provided enough information for the Department of Correction to identify the unnamed defendants. The information concerned sergeants and correctional officers working the 3 p.m. to 11 p.m. shift in specified housing units at the Anna M. Kross Center during Ramadan in 2021 and 2022, as well as the identified religious-services positions at Rikers Island during those periods.
The court ordered the New York City Law Department to determine each unnamed defendant’s identity, badge number, and address for service, and to provide that information to Muflihi and the court within 60 days of the order. Within 30 days after receiving the information, Muflihi must file a second amended complaint naming the defendants. That complaint will replace, rather than supplement, the existing amended complaint. The court stated that it will screen the second amended complaint and, if necessary, issue an order asking the newly named defendants to waive service.
Disposition and Effect
Judge Valerie Caproni’s order addressed service and identification of unnamed defendants. It did not decide the merits of Muflihi’s allegations or determine whether any defendant violated his rights. The case therefore proceeds to the next steps described in the order, including identification of the unnamed defendants and submission of a second amended complaint.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.