In re: Malachi Reynolds

Background

Malachi Reynolds, proceeding without a lawyer, is detained at West Facility on Rikers Island. He filed a lawsuit under 42 U.S.C. § 1983, a federal law allowing claims against state or local actors for violating federal rights. He alleges that conditions at the facility—including sanitation, plumbing, and mail-service conditions—violate his federal constitutional rights. The court had previously allowed him to proceed without paying filing fees in advance.

Adding a Defendant

The complaint did not include a caption naming an opposing party. The Clerk of Court therefore opened the case without a formally designated defendant. Federal Rule of Civil Procedure 21 allows a court, on a party’s motion or on its own, to add or remove a party at any time on fair terms. The court explained that this rule gives courts discretion to organize a case efficiently and fairly, including by adding as a defendant an entity mentioned in the complaint as involved in the alleged events.

The court found that Reynolds clearly intended to assert claims against the City of New York. Because the New York City Department of Correction operates West Facility, the court construed the complaint as asserting claims against the City.

Order

Judge Analisa Torres directed the Clerk of Court to add the City of New York as a defendant under Rule 21 and to notify the New York City Department of Correction and the New York City Law Department. The court requested that the City waive service of the summons. The addition of the City was expressly made without prejudice to any defenses the City may assert. The court also directed the Clerk to mail Reynolds a copy of the order and an information package. The order addresses the case’s parties and service; it does not decide the merits of Reynolds’s constitutional claims.