Williams v. The City of New York

Background

Shamark Williams, proceeding without a lawyer, sued the City of New York and Police Officers Luis A. Segura, Osvaldo J. Garcia, Amandy Feliz, and Dario Albanludena under 42 U.S.C. §§ 1983 and 1988, the Fourth Amendment, and the Fourteenth Amendment. He alleged false arrest, malicious prosecution, and excessive force.

The dispute arose after Richard Watson called 911 on August 27, 2020, reported that Williams had punched him, and identified Williams to responding officers. Officers Segura and Garcia arrested Williams after Watson repeated the accusation. During the arrest, officers tased Williams while attempting to handcuff him. Williams later complained that his handcuffs were too tight. Medical records noted cuff marks and likely nerve damage in his left wrist; Williams testified that he later had surgery.

The criminal charges against Williams were dismissed on speedy-trial grounds on November 17, 2021. Williams then brought this civil case. The City, Segura, and Garcia moved for summary judgment, which asks whether the evidence permits a reasonable jury to find for the opposing party.

Taser and failure-to-intervene claims

The court granted summary judgment to Garcia on the excessive-force claim based on the taser. It found that Williams was resisting arrest, pushing or struggling with officers, and had not yet been handcuffed when Garcia used the taser. Segura had warned Williams that a taser would be used. The court concluded that no reasonable jury could find Garcia’s use of the taser unreasonable under the Fourth Amendment. The court also concluded that Garcia was protected by qualified immunity, a legal protection that generally prevents damages claims against officials unless they violated a clearly established right.

The court also granted summary judgment to Segura on Williams’s claim that Segura failed to intervene in Garcia’s taser use. A failure-to-intervene claim depends on an underlying constitutional violation, and the court had found no viable taser excessive-force claim against Garcia. The court additionally stated that the video showed Segura telling Garcia to stop after the second tasing, and Garcia stopped.

Handcuffing claim

The court denied summary judgment on Williams’s excessive-force claim against Segura based on the handcuffing. The court considered whether the handcuffs were unreasonably tight, whether Segura ignored Williams’s complaints, and the extent of Williams’s wrist injury. Williams testified that the handcuffs tightened because their safety lock had not been engaged, and the record showed that he complained about their tightness while at the precinct. The court found no evidence that Segura checked or loosened the handcuffs.

The court also found evidence of cuff marks and likely nerve damage in Williams’s left wrist, along with Williams’s testimony and video concerning later surgery. It held that a reasonable jury could find that Segura used excessive force. The court further stated that Segura was not entitled to summary judgment based on qualified immunity on this claim because the law clearly established that excessively tight handcuffing after an explicit complaint could violate the Constitution.

False-arrest claim

The court granted summary judgment to Segura and Garcia on the false-arrest claim. It held that Watson’s identification of Williams, Watson’s statement that Williams punched him and caused pain, and swelling observed on Watson’s neck supplied probable cause to arrest Williams for assault. Probable cause means a reasonable basis, based on known facts, to believe that a person committed a crime. The court rejected Williams’s argument that the arrest lacked probable cause because Watson was not injured and held that the officers did not have to investigate every claim of innocence after probable cause existed. The court also held that, at minimum, the officers had arguable probable cause and therefore qualified immunity.

Malicious-prosecution claim

The court granted summary judgment to Segura and Garcia on the malicious-prosecution claim. It concluded that probable cause supported each charged offense addressed in the opinion: third-degree assault, attempted third-degree assault, second-degree aggravated harassment, second-degree harassment, and resisting arrest. The court found no later-discovered fact that eliminated probable cause before the prosecution. It also concluded that the officers were protected by qualified immunity because it was objectively reasonable for them to believe that probable cause supported the charges, or reasonable officers could disagree about that question.

Claims against the City

The court treated Williams’s claims against the City as claims under Monell v. Department of Social Services. Such a claim requires proof of a city policy or custom that caused a constitutional violation. The court granted summary judgment to the City on the false-arrest, malicious-prosecution, and other municipal-liability claims. It reasoned that Williams had not prevailed on the related claims against the individual officers and had not provided evidence of a City policy or practice. The court held that the alleged tight-handcuffing incident, even if unconstitutional, was a single incident and did not establish a municipal policy or custom.

Unserved officers and disposition

The court did not dismiss Feliz and Albanludena for lack of service at that point. Because Williams had been allowed to proceed without paying filing fees and was entitled to service by the U.S. Marshals Service, the court directed that they be served if Williams told the court by September 2, 2025 that he wished to proceed against them. If he did not do so, the court stated that those defendants would be dismissed.

The conclusion states that the motion for summary judgment was “granted in part and dismissed in part.” It specifically grants the motion as to the taser excessive-force, false-arrest, and malicious-prosecution claims against Garcia and Segura, and as to Williams’s municipal-liability claims against the City. It denies the motion as to the handcuffing excessive-force claim against Segura. The Clerk was directed to terminate the motion and the City and Garcia from the action.