Trimm v. New York State Dept. of Corr's and Community Services

Background

Dustin J. Trimm, who was incarcerated at Green Haven Correctional Facility and represented himself, brought claims under 42 U.S.C. § 1983. He alleged that defendants violated the Eighth and Fourteenth Amendments by providing constitutionally inadequate medical care and acting with deliberate indifference to his medical needs. Because the complaint identified Trimm as a convicted and sentenced prisoner rather than a person awaiting trial, the court analyzed only the Eighth Amendment claim.

Trimm alleged that on March 14, 2024, he heard a popping, snapping, or tearing sound in his left leg while walking in the cell block and could not put pressure on the leg. A nurse examined him at the prison infirmary, diagnosed a pulled muscle, and gave him Motrin, a muscle relaxer, and ice. The nurse discharged him over his objection and gave him a clinic appointment slip for medication over the next two days. Trimm alleged that he was denied medication on one of those days because the nurse had issued the wrong permit and had not followed proper procedures. He also alleged that he had experienced leg problems since March 2023 and that several sick-call requests went unanswered.

Trimm sued Commissioner Daniel F. Martuscello, Health Commissioner Carol A. Moorse, Green Haven Superintendent Mark Miller, and Deputy Superintendent for Health Services Billie Tuohy. He also asserted state-law claims involving medical negligence, failure to operate, maintain, or correct, and intentional emotional duress.

Motion and Legal Standards

The defendants moved under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Rule 12(b)(1) permits dismissal when the federal court lacks authority to hear a matter. Rule 12(b)(6) permits dismissal when the complaint does not allege enough facts to state a legally plausible claim. The court was required to read Trimm’s self-represented complaint liberally, but it could not add facts that he had not alleged.

To state a claim under Section 1983, a plaintiff must allege that a defendant, acting under state law, personally deprived him of a federal constitutional or statutory right. The court explained that a supervisor’s position, receipt of complaints, or general responsibility for a facility is not enough to establish personal involvement. A plaintiff must allege a concrete connection between each defendant’s own actions and the claimed injury.

Federal Constitutional Claim

The court held that Trimm failed to allege the personal involvement of any defendant in an Eighth Amendment violation. Trimm argued that he had notified officials with authority over his medical care, and he described each defendant as having broad responsibility for the prison or its medical services. The court found that these allegations did not show that the defendants personally participated in, or caused, the alleged constitutional deprivation.

The court also noted that Trimm’s complaint and correspondence did not clearly establish the extent of any delay in treatment because some documents indicated that he had received medical treatment. The court found that Trimm had not provided facts showing that the alleged delay caused a sufficiently serious injury to support an Eighth Amendment medical-care claim. The deliberate-indifference claim was therefore dismissed.

State-Law Claims

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over Trimm’s remaining claims. Those state-law claims were dismissed without prejudice.

Disposition

Judge Nelson S. Roman granted the defendants’ motion to dismiss. The court dismissed all of Trimm’s claims without prejudice and granted him permission to file an amended complaint by June 23, 2025. The amended complaint was to replace, rather than supplement, the original complaint. The defendants were directed to answer or otherwise respond by July 14, 2025. The court stated that if Trimm failed to file an amended complaint on time and could not show good cause, claims dismissed without prejudice would be deemed dismissed with prejudice.