Morris-Greene v. Doe

Background

Shawn Morris-Greene, who is detained at West Facility on Rikers Island, filed this action without a lawyer under 42 U.S.C. § 1983. The complaint alleges that conditions of confinement involving sanitation, plumbing, and mail service violate federal constitutional rights. The court had previously granted permission to proceed without paying the filing fee in advance.

The complaint did not include a caption identifying a defendant. The clerk therefore captioned the case without a formally designated opposing party.

Court’s action

The court relied on Federal Rule of Civil Procedure 21, which permits a court to add or drop a party on a motion or on its own initiative, on fair terms. The court concluded that, because West Facility is operated by the New York City Department of Correction and because Morris-Greene was representing himself, the complaint clearly intended to assert claims against the City of New York.

The clerk was directed to add the City of New York as a defendant and electronically 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 order stated that adding the City does not prevent it from asserting defenses. The clerk was also directed to mail Morris-Greene a copy of the order and an information package.

Disposition and scope

The court ordered the addition of the City of New York as a defendant. This order addressed the case’s parties and did not resolve the merits of Morris-Greene’s constitutional claims. Judge Analisa Torres signed the order on August 4, 2025.