Carter v. The City of New York
- Laura Swain
- 1:25-cv-03432
- U.S. District Court · Southern District of New York
- 9
Carter v. City of New York: Judge Stanton dismissed Carter’s civil-rights complaint, allowed 30 days to amend, and denied counsel without prejudice.
Jonathan Carter’s claims were dismissed, but he may file an amended complaint within 30 days. The claims against Steven Sternberg, Karman Lam, Detective Desmond Brown, and the City of New York were dismissed for the stated pleading deficiencies; any state-law claims will not be heard in this action unless the court later exercises supplemental jurisdiction. Carter’s request for volunteer counsel was denied without prejudice to renewal.
What happened
In Jonathan Carter v. The City of New York, Carter, who represented himself and was incarcerated, claimed under a federal civil-rights law that officials and attorneys violated his rights through an unfair criminal case, fabricated evidence, and prison conditions. He sought money damages.
The court dismissed the claims against Sternberg and Lam because they were private parties, against Detective Brown because Carter did not describe Brown’s personal involvement, and against the City because Carter did not allege a city policy or practice that caused a constitutional violation. The court also dismissed damages claims challenging Carter’s conviction because those claims could not proceed unless the conviction had been invalidated. It declined to consider any state-law claims.
Judge Louis L. Stanton dismissed the complaint for failure to state a claim but gave Carter 30 days to file an amended complaint. The judge denied Carter’s request for publicly requested volunteer counsel without prejudice to renewing it later and kept the case open while awaiting any amendment.
The detailed version
- Carter v. The City of New York · No. 1:25-cv-03432
- Laura Swain
- July 28, 2025
Background
Jonathan Carter, proceeding without a lawyer and incarcerated at Marcy Correctional Facility, sued the City of New York, Steven Sternberg, Karman Lam, and Detective Desmond Brown under 42 U.S.C. § 1983. He alleged that his federal constitutional rights were violated in connection with his criminal case, including through false statements, fabricated or planted evidence, false charges, and ineffective representation. He also described alleged unsafe conditions at a New York State Department of Corrections and Community Supervision facility, although he did not identify defendants connected with those allegations. Carter sought money damages.
The court screened the complaint under the Prison Litigation Reform Act because Carter was incarcerated and had permission to proceed without prepaying filing fees. The court explained that a complaint must contain enough factual detail to make a claim plausible and must identify how each defendant violated a federal right.
Claims against the private attorneys
The court dismissed Carter’s claims against Steven Sternberg and Karman Lam for failure to state a claim. Section 1983 generally applies only to people acting under government authority. The complaint did not allege that Sternberg or Lam worked for a state or other government body, and representation in a state criminal proceeding does not ordinarily make a private attorney a state actor for purposes of Section 1983.
Claims against Detective Brown
The court dismissed the claims against Detective Desmond Brown because Carter did not allege facts showing Brown’s direct and personal involvement in the alleged constitutional violations. The court granted Carter leave to amend those claims by alleging facts showing how Brown personally participated in violating his rights.
Claims against the City of New York
The court dismissed the claims against the City of New York because Carter did not allege that a city policy, custom, or practice caused the claimed constitutional violation. The court granted leave to amend the claims against the City to address that deficiency.
Challenge to the conviction
The court applied the rule from Heck v. Humphrey, which generally bars a damages claim under Section 1983 when success would necessarily imply that an existing conviction or sentence is invalid, unless the conviction or sentence has already been invalidated. The court concluded that Carter’s damages claims based on an allegedly wrongful conviction involving false or fabricated evidence were inconsistent with his conviction. It therefore dismissed those claims under that rule.
Other claims and request for counsel
The court stated that any claims concerning conditions at Marcy Correctional Facility arose in Oneida County, in the Northern District of New York, and that Carter had not named defendants for those allegations. The court said Carter could assert claims concerning a facility in the Southern District of New York and name an appropriate defendant in an amended complaint.
Because the federal claims were dismissed, the court declined to exercise supplemental jurisdiction—the federal court’s authority to hear related state-law claims—over any state-law claims Carter might be asserting.
The court denied Carter’s application for the court to request volunteer legal counsel without prejudice to renewal at a later time, should he file an amended complaint.
Disposition
Judge Louis L. Stanton dismissed the complaint for failure to state a claim, with 30 days’ leave to replead. The court directed the Clerk of Court to keep the matter open until a civil judgment is entered. If Carter does not file an amended complaint within the allowed period, the court stated that the Clerk will be directed to enter judgment.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.