Middleton v. Lantz

Background

Natalia Danielle Middleton, proceeding without a lawyer and without prepaying filing fees, brought constitutional and state-law claims concerning events on May 1, 2024, and her later involuntary civil commitment. She alleged that police officers used excessive force, handcuffed her, and transported her to Lincoln Medical Center. She further alleged that she did not receive a timely and comprehensive psychiatric evaluation, was involuntarily placed in a psychiatric facility, was forcibly given antipsychotic medication and a sedative, and was held beyond the initial 72-hour evaluation period. She sought damages, an injunction against Lincoln Medical Center, and removal of an alleged misdiagnosis from her medical records.

Claims Against the Individual Defendants

Middleton named Melinda Lantz, Czekierdowski, and Physician’s Assistant Matthew Chiang. The court explained that a claim under 42 U.S.C. § 1983 requires facts showing both a violation of a federal right and action under state law, and that each individual defendant must have been personally involved in the alleged violation. Because the complaint mentioned the individual defendants only in the caption and did not describe what any of them personally did or failed to do, the court dismissed the claims against them for failure to state a claim.

The court also said that Middleton’s allegations about an incomplete evaluation and the lack of written evidence of mental illness or dangerousness were not enough, by themselves, to show that the medical decision was a substantial departure from accepted professional judgment. The court instructed that any amended complaint must describe each defendant’s personal conduct and facts showing that the commitment decision was not based on acceptable professional judgment.

Claim Against Lincoln Medical Center

The court held that Lincoln Medical Center is a facility operated by New York City Health + Hospitals and lacks the legal capacity to be sued independently under New York law. It therefore dismissed the claims against Lincoln Medical Center. The court explained that, if Middleton instead sued Health + Hospitals under § 1983, she would need to allege that a Health + Hospitals policy, custom, or practice caused the constitutional violation; allegations that employees or agents acted wrongfully would not be enough. The court found that the complaint did not allege such a policy, custom, or practice.

Leave to Amend and Disposition

Because Middleton may be able to provide additional facts supporting a valid claim, the court granted her leave to file an amended complaint within 60 days. The amended complaint must completely replace the original complaint, identify the defendants and their personal actions, describe the relevant events and injuries, and state the requested relief. The court allowed the use of John Doe or Jane Doe placeholders for unidentified defendants but warned that doing so does not stop the limitations period from running.

The order stated that no summons would issue at that time. If Middleton does not timely amend and cannot show good cause, the complaint will be dismissed for failure to state a claim. Chief Judge Laura Taylor Swain also certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.