White v. John Doe 1
- Lewis Liman
- 1:24-cv-07905
- U.S. District Court · Southern District of New York
- 2
In White v. John Doe 1, Judge Liman began service steps, requested City of New York waive service, and gave White until September 1, 2025, to identify two Doe defendants.
Sean White, the City of New York, and the unidentified John Doe #1 and John Doe #2 defendants; the New York City Department of Correction and the New York City Law Department were directed to assist with notice and identification.
What happened
White v. John Doe 1 concerns Sean White’s claims that officials were deliberately indifferent to the serious risk from secondhand smoke during his detention at the Robert N. Davoren Center on Rikers Island. He brought the claims under a federal civil-rights law and is representing himself.
The court directed the Clerk to notify the New York City Department of Correction and the New York City Law Department and requested that the City of New York waive service of the summons. The court also said White had not provided enough information for the Department of Correction to identify John Doe #1 and John Doe #2.
Judge Lewis J. Liman gave White until September 1, 2025, to provide descriptive information about the two Doe defendants. The court did not decide the underlying claims in this order and noted that naming Doe defendants does not pause the deadline for bringing claims.
The detailed version
- White v. John Doe 1 · No. 1:24-cv-07905
- Lewis Liman
- July 2, 2025
Background
Sean White, who the opinion says is incarcerated at Lakeview Correctional Facility, filed this action without a lawyer. He alleges under 42 U.S.C. § 1983—a federal law allowing certain civil-rights claims against people acting under state law—that defendants were deliberately indifferent to a serious risk of harm from secondhand smoke while he was detained at the Robert N. Davoren Center on Rikers Island. The court had previously allowed White to proceed without paying court fees in advance, although the opinion notes that prisoners remain responsible for the full filing fee.
Service on the City
The court directed the Clerk of Court to notify the New York City Department of Correction and the New York City Law Department about the order. The court requested that the City of New York waive service of the summons. The order did not state that the City had waived service.
Identifying the John Doe Defendants
White named John Doe #1 and John Doe #2, but the court found that he had not supplied enough information for the Department of Correction to identify them. The court gave examples of missing information, including when the defendants were on duty, where they were located, and their physical descriptions.
If White wished to continue pursuing his claims against the two Doe defendants, the order required him to provide descriptive information to the court and the New York City Law Department by September 1, 2025. The Law Department was then directed to identify the defendants within 30 days after receiving the information or notify the court that the information was insufficient.
Disposition and Effect
Judge Lewis J. Liman issued an order concerning service and identification of defendants. The order did not resolve whether White’s claims were legally or factually valid. The court also noted that naming Doe defendants does not pause the limitations period—the deadline for bringing a claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.