Crumbsie v. Doe
- Clarke
- 7:25-cv-00228
- U.S. District Court · Southern District of New York
- 9
In Crumbsie v. Doe, Judge Clarke ordered the Village Attorney to identify the unnamed officer in Crumbsie’s medical-treatment lawsuit.
Spencer T. Crumbsie must file an amended complaint after receiving the identifying information. The Village Attorney for the Village of Port Chester must identify John Doe, provide his badge number and service address, and the unnamed officer may be named as the defendant.
What happened
In Spencer T. Crumbsie v. John Doe, Portchester Police Station Officer, Spencer T. Crumbsie alleges that a police officer violated his right to adequate medical treatment while he was detained at the Port Chester police station. He is representing himself and sued under a federal civil-rights law.
The officer is identified only as John Doe. Crumbsie provided information about an officer who worked at the station on the morning of July 7, 2024, and arrested him around that date. The court had not decided whether his medical-treatment claim was valid.
Judge Jessica G. L. Clarke ordered the Village Attorney for the Village of Port Chester to find the officer’s identity, badge number, and service address within 60 days. Crumbsie must then file an amended complaint naming the officer within 30 days after receiving that information.
The detailed version
- Crumbsie v. Doe · No. 7:25-cv-00228
- Clarke
- Apr. 8, 2025
Background
Spencer T. Crumbsie, who the opinion says is detained at the Westchester County Jail, filed this action without a lawyer under 42 U.S.C. § 1983. He alleges that John Doe, described as a Portchester police station officer, violated his right to adequate medical treatment while he was detained at the Port Chester police station.
The court had previously allowed Crumbsie to proceed without paying court fees in advance. That permission does not eliminate a prisoner’s obligation to pay the full filing fee under the statute discussed in the opinion.
Identifying the John Doe Defendant
The court relied on the procedure recognized in Valentin v. Dinkins, under which a person representing himself is entitled to the district court’s help identifying a defendant. The court found that Crumbsie’s original complaint and an April 3, 2025 letter supplied enough information to allow identification of the officer who worked at the Port Chester police station on the morning of July 7, 2024, and arrested Crumbsie on or around that date.
Order
The court ordered the Village Attorney of the Village of Port Chester, identified as the attorney and agent for the Port Chester Police Department, to determine John Doe’s identity and badge number and the address where he could be served. The Village Attorney must provide that information to Crumbsie and the court within 60 days of the order.
After receiving the information, Crumbsie must file an amended complaint naming the identified officer within 30 days. The amended complaint will replace, rather than supplement, the original complaint. The court stated that it will screen the amended complaint and may later direct the Clerk of Court and the United States Marshals Service to complete service-related steps.
Disposition and Limits of the Ruling
The court ordered assistance in identifying the unnamed defendant; it did not decide the merits of Crumbsie’s medical-treatment claim. The Clerk of Court was directed to mail the order and specified filings to the Village Attorney and to send Crumbsie an information package.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.