Satchell v. Dept. of Corrections
- Laura Swain
- 1:24-cv-01763
- U.S. District Court · Southern District of New York
- 2
In Satchell v. Dept. of Corrections, Judge Swain dismissed the duplicate lawsuit without prejudice and denied appeal-related IFP status.
John Satchell and the defendants in this duplicate civil-rights action; the ruling leaves Satchell’s related pending case under docket number 23-CV-11119 in place.
What happened
In Satchell v. Dept. of Corrections, John Satchell, who is incarcerated and representing himself, sued under a federal civil-rights law. He alleged unconstitutional conditions while he was held by the New York City Department of Correction between 2019 and 2024.
The court found that Satchell had filed the same amended complaint in another pending case, docket number 23-CV-11119. Because the cases raised the same claims, the court concluded that continuing this duplicate lawsuit would serve no useful purpose.
Chief Judge Laura Taylor Swain dismissed this complaint without prejudice to the pending case. She also denied Satchell’s request to proceed without paying filing fees for an appeal, certified that an appeal would not be taken in good faith, and directed the clerk to enter a civil judgment.
The detailed version
- Satchell v. Dept. of Corrections · No. 1:24-cv-01763
- Laura Swain
- Apr. 22, 2025
Background
John Satchell, who is incarcerated at Clinton Correctional Facility, filed the action without a lawyer and was allowed to proceed without paying the filing fee. He brought claims under 42 U.S.C. § 1983, alleging unconstitutional conditions of confinement while he was in the custody of the New York City Department of Correction between 2019 and 2024. The defendants were identified as Employees Dept of Corrections, the State of New York, several John Does, and a Jane Doe.
The court had previously directed Satchell to amend his original complaint to address deficiencies. Satchell filed an amended complaint on December 4, 2024. The court determined that he had submitted the identical amended complaint in another case pending in the same court, docket number 23-CV-11119. The court therefore found that the present action was duplicative and that no useful purpose would be served by filing and litigating it separately.
Ruling
Chief Judge Laura Taylor Swain dismissed the complaint without prejudice to Satchell’s pending matter under docket number 23-CV-11119. The order did not decide whether Satchell’s conditions-of-confinement claims were legally valid. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal. Finally, the court directed the clerk to enter civil judgment in this case.
Classification
This is a procedural order because the court dismissed the duplicate case without reaching the merits of the constitutional claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.