Morales v. John Doe
- Edgardo Ramos
- 1:25-cv-04170
- U.S. District Court · Southern District of New York
- 3
In Morales v. John Doe, Judge Ramos dismissed the Department of Correction, ordered identification of an unnamed officer, and requested service waivers from other defendants.
Isaac Morales, the Department of Correction, the City of New York, the warden of the Eric M. Taylor Center, and the unnamed correctional officer whose identity the New York City Law Department must investigate.
What happened
In Morales v. John Doe, Isaac Morales, who is detained on Rikers Island and represents himself, claims that officials failed to protect him from an assault at the Eric M. Taylor Center. He sued under a federal civil-rights law several defendants, including an unnamed officer, the facility warden, the City of New York, and the Department of Correction.
The court dismissed the claims against the Department of Correction because it is a city agency that cannot be sued as a separate entity. The court asked the City and the facility warden to waive formal service and directed the New York City Law Department to identify the unnamed officer and provide that officer’s badge number and service address.
Judge Edgardo Ramos gave the Law Department 60 days to provide the information and gave Morales 30 days after receiving it to file an amended complaint naming the officer. The court said it would screen that amended complaint and directed the Clerk to terminate the Department of Correction as a defendant.
The detailed version
- Morales v. John Doe · No. 1:25-cv-04170
- Edgardo Ramos
- July 28, 2025
Background
Isaac Morales, who is detained on Rikers Island and is proceeding without a lawyer, brought this action under 42 U.S.C. § 1983. He alleges that, while detained at the Eric M. Taylor Center, the defendants failed to protect him from an assault by another detainee. The defendants named in the complaint were “B Post Officer John Doe,” the warden of the Eric M. Taylor Center, the City of New York, another “John Doe,” and the New York City Department of Correction.
The court had previously allowed Morales to proceed without paying the filing fee in advance. That permission did not eliminate his obligation to pay the filing fee as required by law.
Rulings
The court dismissed the claims against the Department of Correction because a New York City agency is not a separate entity that can be sued. The Clerk was directed to terminate the Department of Correction as a defendant.
The court requested that the City of New York and the warden of the Eric M. Taylor Center waive service of summons. It also applied the procedure recognized in Valentin v. Dinkins, under which a court assists a self-represented litigant in identifying an unnamed defendant. The court found that Morales had provided enough information for the New York City Law Department to identify “B Post Officer John Doe.”
The Law Department was ordered to provide the officer’s identity, badge number, and address for service to Morales and the court within 60 days. Within 30 days after receiving that information, Morales must file an amended complaint naming the officer. The amended complaint will replace, rather than supplement, the original complaint. The court stated that it will screen the amended complaint and, if necessary, issue a further order concerning service on the newly named defendant.
Effect of the Order
The order resolved the claims against the Department of Correction on the ground that the agency cannot be sued as a separate entity. It did not state a merits ruling on Morales’s allegation that the defendants failed to protect him from assault. The court directed the Clerk to notify the Department of Correction and the New York City Law Department and to mail Morales an information package.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.