Blacknall v. City of White Plains

Background

Dafon Blacknall began this action on August 6, 2024. The court directed service on the City of White Plains and Police Officers Jacobson, Marinello, Valentine, and Velez, and those defendants answered. Blacknall then filed an amended complaint naming Westchester County and Police Officers Smith and Santa. The City and the six identified officers answered the amended complaint. The docket did not show that Westchester County had been served with the amended complaint; the County reported that it had received the initial complaint but not the amended complaint.

Screening standard

The Prison Litigation Reform Act requires federal courts to screen complaints filed by prisoners seeking relief from governmental entities or government officers and to dismiss claims that are frivolous, malicious, fail to state a claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court explained that it must read a self-represented litigant’s pleadings generously, but the complaint must still provide enough facts to make entitlement to relief plausible.

For a claim under 42 U.S.C. § 1983, the plaintiff must allege the defendants’ direct and personal involvement in the alleged constitutional violation. A municipality also cannot be held liable merely because it employed an allegedly misbehaving officer. To state a municipal-liability claim, commonly called a Monell claim, the plaintiff must plausibly allege an official policy or custom that caused the denial of a constitutional right.

Ruling

The court concluded that Blacknall alleged no facts showing that Westchester County was involved in the events underlying his claims. The amended complaint also contained no plausible Monell claim against the County. The court noted that the police officers identified in the amended complaint were employed by the City of White Plains and that the complaint did not otherwise connect Westchester County to the incident.

The court therefore dismissed without prejudice Blacknall’s claims against Westchester County under 28 U.S.C. § 1915(e)(2)(B)(ii). It directed the Clerk of Court to terminate the County as a defendant. Blacknall was given until May 2, 2025, to file a second amended complaint if he could allege the County’s involvement in the events or a plausible connection between the County and the incident sufficient to support a municipal-liability claim.

The court also certified that any appeal from the order would not be taken in good faith and denied fee-free appeal status for that purpose.