Williams, Jr. v. City of New York

Background

Alexander Williams, Jr. sued the City of New York and individual defendants over conditions he experienced as a pretrial detainee at the George R. Vierno Center on Rikers Island. He alleged that a judicial lockdown order and a facility command-level order restricted his housing, movement, visits, telephone calls, property, and access to medical services. He claimed that he was denied treatment for a foot condition, hemorrhoids, mental-health problems, and injuries after exposure to pepper spray. He also alleged that officials prevented or limited his communications with criminal and civil attorneys and retaliated against him for lawsuits, grievances, and publishing a book about Rikers Island.

The defendants jointly moved to dismiss all claims under Rule 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. Williams was proceeding without a lawyer. He abandoned his claims concerning religious observance in his opposition to the motion.

Section 1983 Medical-Care Claims

The court treated Williams’s medical-care allegations as claims under 42 U.S.C. § 1983, a federal statute allowing claims against state actors who violate federal rights. Because Williams was a pretrial detainee, the court analyzed the claims under the Fourteenth Amendment’s protection against unconstitutional conditions of confinement. The court held that the alleged denial of care for his foot, rectal condition, and mental-health problems was sufficiently serious to proceed. It also held that the allegations concerning the pepper-spray exposure stated a plausible claim that Defendant Phillips deliberately withheld care in retaliation for Williams’s prior speech.

The motion was denied on the medical-care claims against Cort and Matos concerning the foot, rectal condition, and mental-health treatment, and against Phillips concerning the pepper-spray incident. The claims against the other individual defendants were dismissed. The court also rejected qualified-immunity arguments at this stage for Matos and Phillips, concluding that the alleged right to necessary medical care was clearly established and that the pleadings did not show that the defendants were entitled to immunity as a matter of law.

Retaliation and Access to Counsel

The court allowed Williams’s First Amendment retaliation claims to proceed against Phillips, Griffin, Cort, Matos, Lindsey-Smith, and Rivera. The allegations included that Phillips withheld medical care because Williams had published a book naming her, and that Lindsey-Smith, Matos, Griffin, Rivera, and Cort participated in or approved restrictions on Williams’s communications with attorneys because of his lawsuits and grievances. The retaliation claims were dismissed against the remaining individual defendants. The court allowed the retaliation claims against the City to proceed except for claims based on Phillips’s conduct, which were dismissed against the City.

The court also allowed Williams’s Sixth Amendment access-to-criminal-counsel claims to proceed against Griffin, Cort, Matos, Lindsey-Smith, Rivera, and the City. It dismissed those claims against the other individual defendants. The court concluded that the alleged restrictions conflicted with orders that permitted attorney communications and that the complaint plausibly alleged retaliatory motives. The Sixth Amendment claims concerning civil counsel did not proceed under the Sixth Amendment, which protects access to counsel for defending criminal charges.

The court dismissed Williams’s equal-protection claim because he alleged that all inmates subject to lockdown orders received the same restrictions, rather than alleging that he was treated differently from similarly situated inmates. The court also dismissed his claims based on his classification as requiring a captain escort because he did not adequately allege that the classification itself was retaliatory.

Municipal Liability

The court allowed some claims against the City under Section 1983. It concluded that Williams plausibly alleged that the command-level order was an official facility policy and that Cort and Matos could have acted as policymakers when they issued and enforced it. The City could therefore remain a defendant on the claims that the order caused denial of treatment for Williams’s foot, rectal condition, and mental-health problems. The City could also remain a defendant on the alleged denial of access to counsel under the First and Sixth Amendments based on alleged conduct by policymakers.

The court dismissed the City’s Section 1983 claim concerning the pepper-spray incident because Williams did not allege that Phillips was a municipal policymaker or that another official with policymaking authority knew about and disregarded that incident.

State-Law Claims

The court declined to dismiss Williams’s individual negligence claims under New York law against Lindsey-Smith, Matos, Cort, Phillips, Rivera, and Griffin. It also declined to dismiss his state-law claims against the City based on negligent supervision and respondeat superior, a theory that can make an employer responsible for certain torts committed by employees acting within the scope of employment. The court dismissed the state-law vicarious-negligence claims against Griffin insofar as they concerned matters other than denial of access to counsel. It dismissed the claims against Cort and Matos concerning the pepper-spray incident but otherwise allowed the specified vicarious-negligence claims to proceed.

The court dismissed all intentional-infliction-of-emotional-distress claims, finding that the alleged denial of medical care and access to counsel did not meet New York’s demanding standard for extreme and outrageous conduct. It allowed Williams’s claims under the New York Constitution to proceed against the specified individual defendants and the City, treating those claims as alternatives to other possible remedies.

The court dismissed Williams’s conspiracy claims under 42 U.S.C. §§ 1985 and 1986. It found that he had not adequately alleged an underlying equal-protection violation or racial or other class-based discriminatory intent. Because a Section 1986 claim depends on a viable Section 1985 claim, the Section 1986 claims were dismissed as well.

Disposition

Judge J. Paul Oetken granted the motion to dismiss in part and denied it in part. For the Section 1983 conditions-of-confinement claims, the motion was denied as to Cort, Matos, Phillips, and the City and granted as to the other defendants. For the First Amendment retaliation claims, the motion was denied as to Phillips, Griffin, Cort, Matos, Lindsey-Smith, Rivera, and the City except for claims based on Phillips’s conduct, and granted as to the other defendants. For the Sixth Amendment claims, the motion was denied as to Griffin, Cort, Matos, Lindsey-Smith, Rivera, and the City and granted as to the other defendants.

The motion was denied as to the individual negligence claims, the City’s supervisory-negligence and respondeat-superior claims, and the New York Constitution claims. It was granted as to the intentional-infliction-of-emotional-distress claims and the Sections 1985 and 1986 conspiracy claims. Defendants were ordered to answer the remaining claims within 14 days after the opinion and order.