Heyward v. Unknown Officers Who Took/Investigated Teresa Moultrie's…
Heyward v. Unknown Officers Who Took/Investigated Teresa Moultrie's Accussations and Issued I-Card
- Laura Swain
- 1:25-cv-02060
- U.S. District Court · Southern District of New York
- 14
In Heyward v. Unknown Officers, Judge Swain granted leave to amend because the complaint did not explain how unidentified officers violated Heyward’s rights.
Michael Heyward must file a more detailed amended complaint within 60 days if he wants to continue this case. The three unidentified New York City Police Department officers are not required to respond unless and until a sufficient amended complaint is filed and the court issues further process.
What happened
In Heyward v. Unknown Officers Who Took/Investigated Teresa Moultrie’s Accusations and Issued I-Card, Michael Heyward alleged that three unidentified New York City police officers mishandled Teresa Moultrie’s accusations in August 2023, leading to an I-Card and periods of detention. He sought money damages and removal of the I-Card.
The court said the complaint did not provide enough facts about what happened, why the officers interviewed Moultrie, whether Heyward was arrested, what charges were involved, or what each officer did. The court also said it was unclear whether this case was related to Heyward’s separate case involving a February 2, 2025 incident.
Judge Laura Taylor Swain granted Heyward 60 days to file an amended complaint with more details and properly identify the defendants. The court did not issue summonses and stated that failure to amend could lead to dismissal for failure to state a claim; it also denied fee-free status for an appeal.
The detailed version
- Heyward v. Unknown Officers Who Took/Investigated Teresa Moultrie's… · No. 1:25-cv-02060
- Laura Swain
- Aug. 19, 2025
Background
Michael Heyward, who was representing himself, sued three unidentified New York City Police Department officers concerning events on August 15 and August 19, 2023. According to the complaint, officers from the 42nd Precinct in the Bronx interviewed Teresa Moultrie. Heyward alleged that the officers failed to investigate or verify an incident discussed with Moultrie and used warrants or an I-Card to disrupt his life. He stated that he was detained for clarification about the I-Card, sometimes spent hours or days behind bars, and was usually not under arrest. He sought money damages and an order eliminating the I-Card attached to his name.
The opinion also notes that Heyward filed another case on the same day concerning a February 2, 2025 incident. In that separate case, he alleged that a desk sergeant at Transit District 12 remanded him because of his criminal history. Heyward referred to that same date and location in this case, creating uncertainty about whether the two cases were related.
Legal standard
Because Heyward had been allowed to proceed without paying filing fees in advance, the court was required to dismiss any part of the complaint that was frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also had to dismiss the case if it lacked subject-matter jurisdiction. The court explained that a complaint must give a short and plain statement showing a plausible entitlement to relief. In reviewing a self-represented complaint, the court must read it liberally and consider the strongest claims reasonably suggested by the allegations, but it need not accept bare legal conclusions.
Court’s analysis
The court found that the complaint did not provide enough information for the court or the defendants to determine whether Heyward plausibly was entitled to relief. Although the complaint appeared to describe two August 2023 events involving three unidentified officers, it did not explain what exactly happened or why each defendant allegedly violated Heyward’s federal rights. The court specifically identified unanswered questions about why the officers interviewed Moultrie, whether Heyward was arrested because of that interview, and what charges, if any, formed the basis for an arrest. Without concrete facts about the August 2023 events, the defendants could not respond adequately.
The court did not decide whether the officers violated Heyward’s rights. Instead, because additional facts might allow him to state a valid claim, it granted him leave to amend. The amended complaint must identify the individuals allegedly involved, using John Doe or Jane Doe descriptions if their names are unknown; explain the relevant events, dates, times, and locations; describe what each defendant did or failed to do; describe his injuries; and state the relief sought. The amended complaint will replace the original complaint, so any facts or claims Heyward wants considered must be repeated in it.
Disposition
The court granted Heyward leave to file an amended complaint within 60 days of August 19, 2025, through the court’s Pro Se Intake Unit, using the label “Amended Complaint” and docket number 25-CV-2060 (LTS). No summons would issue at that time. The court stated that if Heyward failed to comply and could not show good cause, the complaint would be dismissed for failure to state a claim on which relief may be granted. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.