Griffith v. Otis Bantum Correctional Center

Background

Brandon L. Griffith, who was detained at the Otis Bantum Correctional Center (OBCC), brought this action without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against state or local officials for violating constitutional rights. The court had previously allowed him to proceed without prepaying the filing fee.

Griffith originally filed the complaint with 62 other OBCC detainees and described himself as the lead plaintiff. The court had directed the Clerk of Court to separate the individual detainees’ claims into separate cases, leaving Griffith as the only plaintiff in this case.

The complaint contained handwritten allegations from multiple people. It described alleged denial of medical care, general conditions at OBCC, and alleged retaliation for complaints about those conditions. But it did not identify which events happened to Griffith or explain how any particular defendant violated his rights. The complaint named the City of New York, OBCC, Mayor Eric Adams, and Commissioner Lynelle Maginley-Liddie. Correction officers were mentioned but were not named as defendants.

Court’s analysis

The court applied the screening requirements for complaints filed without prepayment of fees. Those requirements require dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, or seek money from an immune defendant. The court also explained that self-represented pleadings are read liberally, but they still must provide enough facts to make a claim plausible and must comply with the rule requiring a short and plain statement of the facts supporting relief.

The court dismissed the claims against OBCC for failure to state a claim because OBCC is a jail operated by the New York City Department of Correction, and the Department of Correction is a city agency that cannot generally be sued separately from the City of New York. The court stated that any claims Griffith intended to bring against OBCC may be asserted against the City.

The court also dismissed Griffith’s claims against Mayor Adams and Commissioner Maginley-Liddie. The order states that official-capacity claims against them may be asserted against the City of New York. It dismissed the personal-capacity claims because Griffith alleged no facts supporting an inference that either official was personally involved in the alleged violations.

The court further found that the complaint did not state Griffith’s own facts or identify the individual officers who allegedly violated his rights. It required any amended complaint to name those individuals, including by using “John Doe” or “Jane Doe” if their names are not known, and to describe each person’s conduct and personal involvement.

Disposition

The court granted Griffith 60 days to file an amended complaint. The amended complaint must replace, rather than supplement, the original complaint and must include the facts and claims Griffith wants the court to consider. It must explain who allegedly violated his federal rights, what each defendant did or failed to do, when and where the events occurred, what injuries resulted, and what relief Griffith seeks.

The court dismissed the claims against Otis Bantum Correctional Center, Mayor Eric Adams, and Commissioner Lynelle Maginley-Liddie. If Griffith does not timely file a compliant amended complaint and cannot show good cause for the delay, the court stated that the complaint will 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 fees for purposes of an appeal from this order.