Campos v. Doe
- Laura Swain
- 1:25-cv-04736
- U.S. District Court · Southern District of New York
- 2
In Campos v. Doe, Judge Torres added the City of New York as a defendant in Campos’s conditions-of-confinement lawsuit.
Vladymir Campos and the City of New York. The City was added as a defendant in Campos’s conditions-of-confinement action, while the New York City Department of Correction and the New York City Law Department were directed to receive electronic notice.
What happened
In Campos v. Doe, Vladymir Campos, who is representing himself and is detained at West Facility on Rikers Island, alleged that sanitation, plumbing, and mail-service conditions violated his federal constitutional rights. The complaint did not identify a defendant in its caption.
The court concluded that Campos clearly intended to sue the City of New York because the facility is operated by the New York City Department of Correction. It directed the Clerk of Court to add the City as a defendant and notify the relevant city agencies. The order did not decide whether Campos’s claims are valid, and the City may assert defenses.
Judge Torres issued the order on August 4, 2025. The court also directed the Clerk to mail Campos a copy of the order and an information package.
The detailed version
- Campos v. Doe · No. 1:25-cv-04736
- Laura Swain
- Aug. 4, 2025
Background
Vladymir Campos is detained at West Facility on Rikers Island and is representing himself. He brought an action under 42 U.S.C. § 1983, a federal law that allows claims against certain government actors for violating constitutional rights. He alleged that conditions at the facility—including sanitation, plumbing, and mail-service conditions—violated his federal constitutional rights.
The complaint did not include a case caption naming an opposing party. As a result, the Clerk of Court initially captioned the case without a formally designated defendant. The court had previously allowed Campos to proceed without paying the filing fee in advance, although the order noted that prisoners remain responsible for the full filing fee under the applicable law.
Court’s Action
The court relied on Federal Rule of Civil Procedure 21, which allows a court to add or remove a party at any time on appropriate terms. The court explained that this rule gives courts discretion to shape a case in the interests of efficiency and justice, including by adding as a defendant an entity mentioned in the complaint as involved in the alleged events.
Because West Facility is operated by the New York City Department of Correction, and because Campos’s complaint showed a clear intention to assert claims against the City of New York, the court construed the complaint as asserting claims against the City. The Clerk of Court was directed to:
- add the City of New York as a defendant under Rule 21; - electronically notify the New York City Department of Correction and the New York City Law Department; and - mail Campos a copy of the order and an information package.
The court requested that the City waive service of the summons. It stated that adding the City was without prejudice to any defenses the City may assert. The order did not resolve the merits of Campos’s constitutional claims.
Disposition and Classification
The court ordered the City of New York added as a defendant. This was an administrative and case-management ruling, not a decision on whether the alleged conditions violated Campos’s constitutional rights. Judge Analisa Torres signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.