Satchell v. Molina
- Gregory Woods
- 1:23-cv-11119
- U.S. District Court · Southern District of New York
- 2
In Satchell v. City of New York, Judge Woods accepted a new complaint, treated earlier claims as withdrawn, and denied the City’s dismissal motion as moot.
John Satchell and the City of New York; the order determines which complaint controls and leaves Satchell’s claims involving unreasonable searches and seizures in the operative pleading.
What happened
In Satchell v. City of New York, John Satchell, who represented himself, filed an amended complaint and later submitted another filing concerning unreasonable searches and seizures. His later filing did not repeat claims about unsafe prison conditions.
The court treated Satchell’s June 6 request as a request for permission to amend. It granted that request and accepted his May 16 filing as the operative Second Amended Complaint. Claims not included in that filing were treated as withdrawn.
Judge Gregory H. Woods denied the City of New York’s motion to dismiss the earlier amended complaint as moot. He also denied fee-free appeal status and directed the Clerk to close the pending motion and mail the order to Satchell.
The detailed version
- Satchell v. Molina · No. 1:23-cv-11119
- Gregory Woods
- June 13, 2025
Background
John Satchell, representing himself, began the case on December 21, 2023. He filed an Amended Complaint on December 4, 2024. The court ordered him to provide more information about unidentified defendants and later asked him to clarify the dates and locations involved in his allegations. Satchell did not provide that clarification, but instead filed additional letters reasserting some allegations.
The court previously explained that Satchell’s new allegations would not be treated as amended pleadings unless he formally requested permission to amend or obtained the defendants’ consent. The court also explained that an accepted amended complaint would replace, rather than supplement, the earlier complaint.
Later Filing and Motion
The City of New York moved to dismiss the Amended Complaint on April 28, 2025. On May 16, Satchell filed a letter formatted as an amended complaint. That filing reasserted claims involving unreasonable searches and seizures but did not repeat the allegations or claims concerning unsafe prison conditions. The court initially declined to accept the filing as an amended pleading because Satchell had not requested permission to amend.
On June 6, Satchell sent a letter explicitly requesting permission to amend and stating that he wanted to proceed with the May 16 filing.
Ruling
The court granted Satchell’s request for permission to amend and accepted the May 16 filing as the operative Second Amended Complaint. The court stated that any claims not raised in that complaint were deemed withdrawn.
Because the earlier Amended Complaint was no longer the operative pleading, the court denied the City of New York’s motion to dismiss that complaint as moot. The court also certified that an appeal from the order would not be taken in good faith and denied Satchell fee-free status for purposes of an appeal. The Clerk was directed to terminate the pending motion and mail Satchell a copy of the order by certified mail.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.