Juares v. Odyssey House NYC Inc.

Background

Alexis Juares, proceeding without a lawyer, sued Odyssey House NYC Inc.; Shateek Bilal, identified as Juares’s Odyssey House counselor; and the New York State Office of Addiction Services and Supports (OASAS). Juares brought claims under 42 U.S.C. § 1983, a federal law allowing certain claims for violations of constitutional rights by people acting under state authority. He alleged that on August 13, 2024, Bilal accused him of not attending an acting class, although an investigation showed that Juares attended and signed the attendance sheet. Juares further alleged that Bilal prepared a behavioral mandate agreement, tried to obtain supporting statements from two other clients, and negatively affected his mandate, including by contributing to its extension. Juares sought $40 million in damages.

Court’s analysis

Because Juares was allowed to proceed without paying filing fees, the court was required to screen the complaint. It had to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s authority. The court also explained that although it must read a self-represented person’s allegations liberally, the complaint still must provide enough facts to make liability plausible.

The court dismissed the claims against Odyssey House and Bilal for failure to state a claim. Private parties generally are not liable under § 1983 unless their conduct qualifies as government action. One way private conduct can qualify is when a private party and a government actor jointly participate in the conduct that caused the alleged injury. The court found that Juares did not allege facts supporting an inference that Bilal and a state actor acted jointly to cause the extension of his court mandate. The court specifically noted that the complaint did not suggest that a state actor advocated for extending the mandate.

The court also dismissed Juares’s § 1983 claims against OASAS because the agency is an arm of New York State and is protected by the Eleventh Amendment from this type of federal lawsuit. The court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—because it had dismissed all claims over which it had original federal jurisdiction.

Disposition

The court dismissed the complaint for failure to state a claim and granted Juares 30 days’ leave to amend and replead. The court stated that an amended complaint must allege enough facts to support an inference that Odyssey House and/or Bilal worked jointly with a state employee. If Juares did not file an amended complaint within the permitted time, the clerk would be directed to enter judgment. The court denied Juares’s request for pro bono counsel without prejudice to renewing that request later and directed the clerk to keep the matter open until a civil judgment was entered. Judge Louis L. Stanton signed the order.