Rodriguez v. Morton Williams
- Kimba Wood
- 1:25-cv-03775
- U.S. District Court · Southern District of New York
- 6
In Rodriguez v. Morton Williams, Judge Wood dismissed the complaint for failure to state a claim, allowing amendment within 30 days.
Jose A. Rodriguez’s complaint was dismissed because it did not allege that the defendants acted under state authority. He may file an amended complaint within 30 days; the court declined to exercise supplemental jurisdiction over any state-law claims he may be asserting.
What happened
In Rodriguez v. Morton Williams, Jose A. Rodriguez alleged that a Morton Williams store, its owner, a security guard, and a manager falsely accused him of shoplifting and detained him for about an hour, even though he had paid and had a receipt. Rodriguez represented himself and sought money damages.
The court treated the allegations as constitutional claims under Section 1983, a federal law that generally requires defendants to have acted for the government. The court said Rodriguez did not allege facts showing that any defendant was a state actor. After dismissing the federal claims, the court declined to decide any state-law claims that Rodriguez may have been asserting.
Judge Kimba Wood dismissed the complaint for failure to state a claim but granted Rodriguez 30 days to file an amended complaint alleging that a state actor violated his rights and explaining each defendant’s involvement. The court also denied fee-free status for any appeal and said the Clerk should enter judgment if Rodriguez does not amend within the allowed time.
The detailed version
- Rodriguez v. Morton Williams · No. 1:25-cv-03775
- Kimba Wood
- June 25, 2025
Background
Jose A. Rodriguez, appearing without a lawyer, brought the action under the court’s federal-question jurisdiction and sought money damages. He alleged that on April 26, 2025, at a Morton Williams store on East Kingsbridge Road in the Bronx, he was falsely accused of shoplifting and detained for about one hour. Rodriguez alleged that he had paid, had a receipt, and that checking the cameras confirmed that he had not stolen anything.
The defendants were Morton Williams; Morton Williams, owner; Francisco—last name unknown, identified as a security guard; and an unknown manager who was on duty at the relevant time.
Legal Standard
Because Rodriguez had been allowed to proceed without prepaying filing fees, the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B). That law requires dismissal of an action that is frivolous or malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also explained that a self-represented plaintiff’s allegations are read liberally, but the complaint still must provide enough facts to make a claim plausible and must comply with Rule 8’s requirement of a short and plain statement showing entitlement to relief.
Section 1983 Claims
The court construed the complaint as asserting constitutional claims under 42 U.S.C. § 1983. A Section 1983 claim requires facts showing that each defendant acted under color of state law—that is, using authority or conduct attributable to a state or local government. Private parties generally are not liable under Section 1983, and private security guards generally are not state actors for this purpose. The court noted that some security guards may qualify as specially appointed patrolmen with police powers, but Rodriguez did not allege that the security guard had such an appointment.
The court concluded that Rodriguez did not allege that Morton Williams, its owner, or its manager worked for a state or other government body, and did not allege facts showing that the security guard was a specially appointed patrolman. The court therefore dismissed the complaint for failure to state a claim under Section 1915(e)(2)(B)(ii). The court also directed that any amended complaint allege facts suggesting that a state actor violated Rodriguez’s rights and explain how each named defendant was personally involved.
State-Law Claims
The court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—because it had dismissed the federal claims over which it had original jurisdiction. The opinion refers to any state-law claims Rodriguez may have been asserting; it does not identify specific state-law causes of action.
Leave to Amend and Disposition
The court granted Rodriguez 30 days to file an amended complaint. If he does not file one within that period, the court stated that the Clerk will be directed to enter judgment in the action. The court also certified that any appeal would not be taken in good faith and denied Rodriguez the ability to proceed without prepaying fees for an appeal. The Clerk was directed to keep the matter open on the docket until a civil judgment is entered.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.