Satchell v. The City of New York
- Laura Swain
- 1:25-cv-03515
- U.S. District Court · Southern District of New York
- 2
In Satchell v. Employees Dept of Corrections, Judge Swain dismissed a duplicate COVID-exposure lawsuit without prejudice.
John Satchell and the defendants named in this duplicate lawsuit; the order also directs the Clerk and the official holding Satchell’s prison trust account not to collect the filing fee for this action.
What happened
In John Satchell v. Employees Dept of Corrections, Satchell, who is incarcerated and representing himself, sued under a federal civil-rights law. He alleged that correctional staff subjected him to unconstitutional conditions by unnecessarily exposing him to COVID-19 while he was in Department of Correction custody.
The court dismissed this lawsuit without prejudice to Satchell’s pending case under docket number 23-CV-11119 because the two actions raised the same claims. The court also directed the Clerk not to charge the $350 filing fee for this case or deduct funds from Satchell’s prison account for it.
Judge Laura Taylor Swain certified that an appeal would not be taken in good faith and denied fee-free status for an appeal. She also directed the Clerk to enter civil judgment.
The detailed version
- Satchell v. The City of New York · No. 1:25-cv-03515
- Laura Swain
- May 5, 2025
Background
John Satchell, who is incarcerated at Clinton Correctional Facility, filed the action without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against government actors for violations of constitutional rights. He alleged that correctional staff subjected him to unconstitutional conditions of confinement by unnecessarily exposing him to COVID-19 while he was in the custody of the New York City Department of Correction.
The opinion states that Satchell had already filed a related case involving the same alleged COVID-19 exposure while in Department of Correction custody. That matter was pending under docket number 23-CV-11119. The court also noted that Satchell had filed another action concerning his conditions of confinement, which had been dismissed as duplicative.
Court’s Reasoning
The court concluded that this complaint duplicated the claims in the pending case. Because the same claims were already being litigated, the court determined that filing and litigating this separate lawsuit would serve no useful purpose. The opinion also states that claims concerning events at Clinton Correctional Facility would not have proper venue in the Southern District of New York because Clinton County is in the Northern District of New York; however, the dismissal order rested on the complaint’s duplicative nature.
Ruling
Judge Laura Taylor Swain dismissed the complaint without prejudice to the matter pending under docket number 23-CV-11119. The court directed the Clerk not to charge Satchell the $350 filing fee for this action, and directed that funds not be deducted or encumbered from his prison trust account for this lawsuit.
The court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied fee-free status for purposes of an appeal. It also directed the Clerk to enter civil judgment.
Effect of the Order
The order ended this duplicate case, while leaving the pending matter under docket number 23-CV-11119 unaffected as stated in the order. The opinion does not decide whether Satchell’s COVID-exposure allegations have merit.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.