Jackson v. Bonaparte
- James Oetken
- 1:25-cv-00811
- U.S. District Court · Southern District of New York
- 8
Jackson v. Bonaparte: Judge Figueredo ordered proper service and an amended ADA complaint, if pursued, naming the Department of Corrections.
Dyron Morris Jackson, the defendants he attempted to serve, and the Department of Corrections as the entity the court identified for any ADA claim Jackson wishes to pursue.
What happened
In Jackson v. Bonaparte, Dyron Morris Jackson submitted documents saying he served the defendants by certified U.S. mail. The court said that method generally was not proper without prior approval after attempts at personal service.
The court directed Jackson to serve the summons and complaint under Federal Rule of Civil Procedure 4 by August 20, 2025. It also explained that the Americans with Disabilities Act does not allow claims against individual defendants; if Jackson wants to pursue that claim, he must amend the complaint before serving the defendants to name the Department of Corrections.
Judge Valerie Figueredo issued the order. The order addressed service and the proper defendant for the ADA claim; it did not decide the underlying claims.
The detailed version
- Jackson v. Bonaparte · No. 1:25-cv-00811
- James Oetken
- July 24, 2025
Background
Dyron Morris Jackson submitted affidavits stating that the defendants were served on May 30, 2025, by certified U.S. mail. The court explained that certified-mail service is generally not proper unless the court approves it after attempts at personal service by someone other than the plaintiff.
Court’s directions
The court directed Jackson to serve the summons and complaint on the defendants according to Rule 4 of the Federal Rules of Civil Procedure. It set August 20, 2025, as the deadline for completing that service and attached instructions describing permitted service methods.
The court also advised that the Americans with Disabilities Act of 1990 does not impose individual liability. Therefore, Jackson’s ADA claim could not proceed against the individual defendants as named. If Jackson wished to pursue an ADA claim, the court directed him to amend the complaint before serving the defendants and name his employer, the Department of Corrections, as a defendant.
Effect of the order
This was a procedural order addressing service and the proper defendant for the ADA claim. The order did not decide the merits of Jackson’s underlying claims.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.