Maxwell v. Rikers Island

Background

Charles Maxwell brought this action without a lawyer under 42 U.S.C. § 1983, alleging that defendants used excessive force against him during his detention in the Otis B. Bantum Center. He identified Rikers Island and four unnamed correction officers as defendants. The opinion states that Maxwell is incarcerated at the Robert N. Davoren Center on Rikers Island. The court had previously granted him permission to proceed without prepaying filing fees.

Screening and Rikers Island

Because Maxwell is a prisoner seeking relief against governmental defendants, the court reviewed the complaint under the Prison Litigation Reform Act. That review requires dismissal of claims that are frivolous, malicious, inadequately pleaded, seek money from an immune defendant, or fall outside the court’s jurisdiction.

The court explained that Rikers Island is a facility operated by the New York City Department of Correction and that, under New York law, the Department and its facilities cannot be sued as separate entities. The court therefore dismissed Maxwell’s claims under Section 1983 against Rikers Island under 28 U.S.C. § 1915(e)(2)(B)(ii).

Because Maxwell was representing himself and appeared to intend to assert claims against New York City, the court construed the complaint as asserting claims against the City and directed the clerk to add the City as a defendant. The court stated that this amendment was without prejudice to defenses the City might assert. The court also directed the clerk to notify the Department of Correction and the New York City Law Department and requested that the City waive service of the summons.

Unnamed correction officers

The complaint identified four unnamed correction officers who allegedly escorted Maxwell from the medical unit back to the Otis B. Bantum Center on April 4, 2025, between approximately 11:00 a.m. and 12:00 p.m. The court directed the New York City Law Department to determine each officer’s identity and badge number and provide an address where the officer could be served. The Law Department must provide that information to Maxwell and the court within 60 days of the order.

Within 30 days after receiving the information, Maxwell must file an amended complaint naming the officers. The amended complaint will replace, rather than add to, the original complaint. The court stated that it will screen the amended complaint and, if necessary, issue an order concerning service.

Discovery and disposition

The court ruled that Local Civil Rule 33.2 applies. Under that rule, within 120 days after service of the complaint, the defendants must respond to the specified prisoner-case discovery requests and quote each request verbatim in their responses.

The order dismisses Maxwell’s claims against Rikers Island and directs the clerk to add New York City as a defendant. It does not state that the court decided whether excessive force occurred. Judge Ronnie Abrams signed the order on May 21, 2025.