Alfonso v. Otis Bantum Correctional Facility

Background

Jensi Alfonso, who was detained at the Otis Bantum Correctional Center (OBCC), brought a self-represented action under 42 U.S.C. § 1983, a federal law allowing claims against state or local actors for violating federal rights. The court had already granted Alfonso permission to proceed without prepaying filing fees.

Alfonso initially filed the action with 62 other OBCC detainees. The court later separated the claims of each individual plaintiff into separate civil actions. In Alfonso’s case, the complaint contained different handwritten sections prepared by different people and described alleged denial of medical care, general conditions at OBCC, and retaliation for complaints about those conditions. The allegations were written from the perspective of the group and did not explain Alfonso’s individual experiences or identify how a particular defendant violated his rights.

The defendants named in the complaint were the City of New York, OBCC, Mayor Eric Adams, and Commissioner Lynelle Maginley-Liddie. Correction officers were mentioned but were not named as defendants.

Screening standard

Because Alfonso was proceeding without prepayment of fees, the court was required to dismiss any claim that was frivolous, malicious, failed to state a legally valid claim, sought money from an immune defendant, or fell outside the court’s jurisdiction. The court also explained that although it must read self-represented pleadings liberally, a complaint still must provide enough factual detail to make a claim plausible and must comply with the requirement of a short and plain statement showing entitlement to relief.

Rulings on the defendants

The court dismissed the claims against OBCC for failure to state a claim. It held that OBCC is a jail operated by the New York City Department of Correction and is not an entity that can be sued under the New York City Charter. The court stated that any claims Alfonso intended to bring against OBCC could be asserted against the City of New York.

The court dismissed the official-capacity claims against Adams and Maginley-Liddie. An official-capacity claim is treated as a claim against the government entity the official represents, so those claims were treated as claims against the City of New York.

The court also dismissed the personal-capacity claims against Adams and Maginley-Liddie. A personal-capacity claim requires facts showing that the defendant was personally involved in the alleged constitutional violation. The court found that Alfonso alleged no facts showing either official’s personal involvement. It also explained that officials cannot be held liable under § 1983 merely because they supervise someone who allegedly violated a person’s rights.

Leave to amend

The court granted Alfonso 60 days to file an amended complaint. The amended complaint must identify the individuals who allegedly violated his rights, name them in the caption and statement of claim, and provide facts explaining what each person did or failed to do, when and where the events occurred, the injuries Alfonso suffered, and the relief he seeks. If Alfonso does not know an individual’s name, he may use a John Doe or Jane Doe designation, but the court stated that doing so does not stop the limitations period from running.

The amended complaint will replace the original complaint rather than supplement it, so Alfonso must repeat any facts or claims from the original complaint that he wants the court to consider. The court directed him to label the filing “Amended Complaint” and use docket number 24-CV-9640 (LTS). No summons would issue at that time.

Disposition

The court granted leave to amend. It dismissed Alfonso’s claims against OBCC, Adams, and Maginley-Liddie under the federal screening statute. The official-capacity claims against Adams and Maginley-Liddie may be asserted against the City of New York, while their personal-capacity claims were dismissed for failure to allege personal involvement. The court stated that if Alfonso failed to amend within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also denied permission to appeal without prepaying fees after certifying that an appeal would not be taken in good faith. Judge Laura Taylor Swain signed the order.