Urena v. The City of New York

Background

Amaury Urena, who was incarcerated at the George R. Vierno Center on Rikers Island and represented himself, sued the City of New York and Dr. McCrimons under 42 U.S.C. § 1983. He alleged that on December 12, 2023, at about 9:00 p.m. at St. Barnabas Hospital, Dr. McCrimons told him that his blood would be drawn to search it. Urena alleged that he refused and did not consent, but Dr. McCrimons said the blood would be taken forcibly and then drew it. Urena asserted violations of the Fourth and Fourteenth Amendments and sought $10 million in damages.

The court had previously allowed Urena to proceed without paying filing fees in advance. Because Urena was incarcerated and sought relief from governmental defendants, the court screened the complaint under the Prison Litigation Reform Act. At that stage, the court had to dismiss claims that were frivolous, malicious, failed to state a legally valid claim, or sought relief from an immune defendant.

Claims Against the City

The court held that the complaint did not satisfy Federal Rule of Civil Procedure 8, which requires enough factual detail to give a defendant fair notice of the claim and show that relief is plausible. Urena did not describe the circumstances surrounding the attempted blood draw, including whether there was a medical emergency or another relevant situation. He also did not provide facts explaining why the City of New York was responsible, particularly because the opinion states that St. Barnabas Hospital was not operated by the City.

The court dismissed Urena’s claims against the City for failure to state a claim. It explained that a municipality cannot be held liable under § 1983 merely because one of its employees or agents allegedly committed wrongdoing. Urena would need to allege facts showing that a City policy, custom, or practice caused the alleged constitutional violation.

Claims Against Dr. McCrimons

A § 1983 claim requires facts showing that the defendant acted under color of state law—that is, used authority connected to state or local government. Private parties generally are not liable under § 1983. A private physician providing medical services to prisoners can sometimes meet this requirement when treating prisoners on behalf of government authorities.

The court found that Urena had not alleged whether he was in custody when the blood draw occurred or whether Dr. McCrimons was treating him on behalf of government authorities. Because the complaint did not allege that Dr. McCrimons worked for the government or was performing a government function, the court concluded that Urena had not stated a § 1983 claim against him.

State-Law Claims and Leave to Amend

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over any state-law claims Urena may have asserted.

The court granted Urena 60 days to amend because additional facts might allow him to state a valid federal claim. An amended complaint must replace the original rather than supplement it. The court directed Urena to identify the relevant people and their roles, describe what each defendant did or failed to do, provide approximate dates, times, and locations, describe his injuries, and identify the relief sought. If he did not amend within the permitted period and could not show good cause for the failure, the court stated that the complaint would be dismissed for failure to state a claim. The clerk was directed to keep the matter open until judgment is entered.

Disposition

Judge Louis L. Stanton dismissed Urena’s § 1983 claims, declined supplemental jurisdiction over any state-law claims, and granted 60 days’ leave to file an amended complaint.