Barnett v. State of New York
- Philip Halpern
- 7:24-cv-01174
- U.S. District Court · Southern District of New York
- 4
In Barnett v. Thomas, Judge Halpern denied referral and discovery requests, granted amendment in part, and extended Barnett’s filing deadline.
LAFVORNE BARNETT and the defendants—C.O. A. Thomas, C.O. K. Edwards, C.O. M. Banks, and the proposed additional defendants—were affected. Barnett could add the proposed John and Jane Doe defendants but not the State of New York; his discovery requests and request for referral were denied, with the request for unredacted reports denied without prejudice.
What happened
In Barnett v. C.O. A. Thomas, LAFVORNE BARNETT, who was representing himself, asked the court to refer the case to a magistrate judge, require additional discovery, and let him add the State of New York and unidentified defendants. The defendants opposed the requests.
The court denied referral because the defendants did not agree to have a magistrate judge handle the case for all purposes. It denied the discovery request for video because the defendants said no recording had been found, and denied other discovery requests as moot because the requested reports had already been produced or were covered by an earlier order. It denied without prejudice the request for unredacted reports because they contained the defendants’ private medical information.
Judge Halpern denied permission to add the State of New York, but granted permission to add the proposed unidentified defendants, so the motion to amend was granted in part. The court extended the deadline for Barnett to file his Second Amended Complaint to June 25, 2025.
The detailed version
- Barnett v. State of New York · No. 7:24-cv-01174
- Philip Halpern
- June 6, 2025
Background
LAFVORNE BARNETT, who was proceeding without a lawyer, brought the action against C.O. A. Thomas, C.O. K. Edwards, and C.O. M. Banks. The court had previously allowed Barnett to add Sergeant Theodore Brooks and had set June 9, 2025, as the deadline for a Second Amended Complaint. Barnett later submitted a letter asking the court to refer the case to a magistrate judge for all purposes, compel additional discovery, and allow him to add the State of New York and unidentified “John” and “Jane” Doe defendants. The court treated the letter as a motion containing those three requests. The defendants opposed it.
Referral to a Magistrate Judge
The court denied the request to refer the case to a magistrate judge for all purposes because the defendants did not consent to that arrangement.
Discovery Requests
Barnett sought four categories of materials:
- Use-of-force video: The court denied this request because the defendants represented that they had made multiple inquiries but had not identified any video recording of the December 19, 2023 incident at Sing Sing.
- Unusual Incident and Use of Force Reports: The court denied this request as moot because the defendants represented that they had produced the reports on March 20, 2025, and again on May 13, 2025, in color.
- Medical report: The court denied this request as moot because an earlier order had provisionally granted Barnett’s request for his medical records, subject to his signing and returning the required medical-information release.
- Unredacted reports: The court understood Barnett to also seek unredacted copies of the incident and use-of-force reports. It denied that request without prejudice because the redactions protected the defendants’ private medical information and Barnett had not explained why the defendants’ medical conditions were relevant to his civil-rights claims under Section 1983, the federal law authorizing certain claims against state actors. The court stated that Barnett could renew the request if he explained that relevance.
Leave to Amend
The court denied Barnett’s request to add the State of New York, relying on its earlier ruling that his Section 1983 claims against the State were barred by the Eleventh Amendment. The court permitted Barnett to add the proposed John and Jane Doe defendants, while reminding him that he must provide enough information to help identify them.
Disposition
Judge Philip M. Halpern concluded that the motion to amend the operative pleading was granted in part. The motion to refer the case to a magistrate judge for all purposes and the motion to compel were denied. The court extended the deadline for Barnett to file his Second Amended Complaint to June 25, 2025. The defendants were directed, within fourteen days after that complaint was docketed, either to answer it or move to dismiss under the court’s individual rules.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.