Felix v. Doe

Background

David Felix is detained at West Facility on Rikers Island and is proceeding without a lawyer. He brings an action under 42 U.S.C. § 1983, a federal law that permits claims for violations of constitutional rights by state or local officials, alleging that conditions at the facility violate his federal constitutional rights. The opinion identifies sanitation, plumbing, and mail service as examples of the challenged conditions.

The court had previously allowed Felix to proceed without paying filing fees in advance. His complaint did not include a caption identifying an opposing party, so the clerk initially captioned the case without a formally designated defendant.

Ruling

The court applied 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 it may use this rule to add a defendant who is discussed in the body of a complaint as being involved in the alleged events.

Because the New York City Department of Correction operates West Facility, and because Felix’s complaint clearly showed an intent to assert claims against the City of New York, the court construed the complaint as asserting claims against the City. It directed the clerk to add the City of New York as a defendant and to 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 and directed the clerk to mail Felix a copy of the order and an information package.

The amendment was without prejudice to any defenses the City of New York may assert. The order addressed the proper defendant and case administration; it did not decide the merits of Felix’s conditions-of-confinement claims.