Thomas v. City of New York
- Valerie Caproni
- 1:24-cv-02534
- U.S. District Court · Southern District of New York
- 5
In Thomas v. City of New York, Judge Caproni ended several claims, allowed others to proceed, and permitted limited amendment of the complaint.
Shawn Randall Thomas’s claims were partly ended and partly allowed to proceed. The City and Officers Barcenas, Rigsang, Baroz, and Pitt obtained summary judgment on the false-arrest, false-imprisonment, and malicious-prosecution claims. Mayor Adams obtained dismissal of the claims against him, subject to limited amendment of the personal-capacity claims. Claims concerning unconstitutional detention conditions and involuntary psychiatric evaluation remain against Officers Dunigan, Herrera, Azzolino, and Rigsang.
What happened
Shawn Randall Thomas, representing himself, sued New York City, Mayor Eric Adams, former Police Commissioner Keechant Sewell, and police officers under federal civil-rights law. He claimed false arrest, false imprisonment, malicious prosecution, emotional distress, unconstitutional detention conditions, and involuntary psychiatric evaluation.
No party objected to the magistrate judge’s recommendations. The court therefore reviewed them for clear error and adopted them in full. Several claims were resolved, while claims about detention conditions and involuntary psychiatric evaluation were allowed to continue against four officers.
Judge Caproni granted Mayor Adams’s motion to dismiss, granted summary judgment for the City and four officers on the false-arrest, false-imprisonment, and malicious-prosecution claims, and dismissed other claims. She denied judgment on the pleadings as to the detention-condition and psychiatric-evaluation claims and allowed limited amendment.
The detailed version
- Thomas v. City of New York · No. 1:24-cv-02534
- Valerie Caproni
- Aug. 22, 2025
Background
Shawn Randall Thomas, proceeding without a lawyer, sued the City of New York, Mayor Eric Adams, former New York City Police Department Commissioner Keechant Sewell, and several police officers in their personal and official capacities. He asserted claims under 42 U.S.C. § 1983, a federal law that allows claims against government officials for violating federal rights. His claims concerned false arrest, false imprisonment, malicious prosecution, intentional infliction of emotional distress, unconstitutional conditions of confinement while in police custody, and involuntary psychiatric evaluation.
Mayor Adams moved to dismiss for failure to state a claim. The City and the officer defendants later moved for judgment on the pleadings, which asks whether the complaint and the defendants’ answers show that a party is entitled to judgment. The magistrate judge issued two reports and recommendations addressing those motions. No party filed objections.
Rulings
The court found no clear error in the magistrate judge’s recommendations and adopted both reports in full.
The court granted Mayor Adams’s motion to dismiss. Under the adopted recommendation, Thomas’s claims against Adams in his official capacity were dismissed with prejudice, while his claims against Adams in his personal capacity were dismissed without prejudice. The court gave Thomas permission to amend his complaint to address the deficiencies identified in the recommendation concerning the personal-capacity claims.
For the City and Officers Kevin Barcenas, Tenzin Rigsang, Michael Baroz, and Dyshawn Pitt, the court converted the motion for judgment on the pleadings into a motion for summary judgment only as to the false-arrest, false-imprisonment, and malicious-prosecution claims. The court granted summary judgment in their favor on those claims.
The court dismissed with prejudice Thomas’s intentional-infliction-of-emotional-distress claim against the City and Officers Michael Dunigan, Tenzin Rigsang, and Dyshawn Pitt. It dismissed without prejudice Thomas’s municipal-liability claim against the City. Thomas was permitted to amend that claim as well; the order states that failure to amend would result in dismissal with prejudice.
The court denied the motion for judgment on the pleadings as to Thomas’s claims concerning unconstitutional conditions of confinement and involuntary psychiatric evaluation against Officers Michael Dunigan, Andy Herrera, Nicholas Azzolino, and Tenzin Rigsang. Those claims may proceed against those officers.
Other Orders
Because no party objected to the recommendations after receiving notice that objections were required, the court stated that appellate review of the decision was precluded. It also denied permission to appeal without paying the filing fees, finding that any appeal would not be taken in good faith. Thomas’s deadline to amend was September 19, 2025, and the defendants’ deadline to answer was October 10, 2025. The order also notes that former Commissioner Sewell had never been served.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.