Abdul-Aleem v. Miller
Yahya Abdul-Aleem v. Mark Miller; Michael Lago; D. Strong; Michelle M. Liberty; John Doe #1; John Doe #2; Cathy Y. Sheehan; Jane Doe #1; Jane Doe #2
- Clarke
- 7:24-cv-09097
- U.S. District Court · Southern District of New York
- 2
In Yahya Abdul-Aleem v. Miller, Judge Clarke ordered a pro se amended complaint naming Christa Lloyd and barred renaming the dismissed John Does.
Yahya Abdul-Aleem; Christa Lloyd, identified as Jane Doe #1; the unidentified Jane Doe #2; and the previously dismissed John Doe #1 and John Doe #2.
What happened
Yahya Abdul-Aleem, who is incarcerated, sued several defendants without a lawyer, claiming violations of his Eighth and Fourteenth Amendment rights. The court had dismissed two John Doe defendants because the complaint did not provide enough information to identify them.
Defendants identified Jane Doe #1 as social worker Christa Lloyd but could not identify Jane Doe #2. The court ordered Abdul-Aleem to file an amended complaint by October 30, 2025, updating the caption to name Lloyd. The court said he could later seek another amendment if discovery provides enough information to identify Jane Doe #2.
Judge Jessica G. L. Clarke also clarified that the amended complaint may not rename the already-dismissed John Doe defendants. The order did not decide whether Abdul-Aleem’s constitutional claims have merit and allowed him to add Alissa Davis as a plaintiff only if Davis seeks to join the case without a lawyer.
The detailed version
- Abdul-Aleem v. Miller · No. 7:24-cv-09097
- Clarke
- Sept. 2, 2025
Background
Yahya Abdul-Aleem, who is incarcerated at Green Haven Correctional Facility, brought this action without a lawyer, alleging violations of his rights under the Eighth and Fourteenth Amendments. The complaint named Mark Miller, Michael Lago, D. Strong, Michelle M. Liberty, Cathy Y. Sheehan, two John Doe defendants, and two Jane Doe defendants.
In an earlier order, the court dismissed John Doe #1 and John Doe #2 because the complaint lacked information identifying them. The court directed the defendants to identify the Jane Doe defendants and granted the Office of the Attorney General several extensions to do so. The court had also told Abdul-Aleem that he could file an amended complaint after reviewing the defendants’ response.
Identification of Jane Doe Defendants
By letter dated August 29, 2025, the defendants identified Jane Doe #1 as social worker Christa Lloyd. They stated that they could not identify Jane Doe #2 from the information in the original complaint.
The court declined to issue another order requiring identification at that time. Instead, it directed Abdul-Aleem to amend his complaint using the information currently available. The court stated that, if discovery later provides enough information to identify Jane Doe #2, it will give Abdul-Aleem another opportunity to amend the complaint.
Order
The court ordered Abdul-Aleem to file an amended complaint by October 30, 2025. The amended complaint must update the caption to identify Jane Doe #1 as Christa Lloyd. The court also stated that Abdul-Aleem may add Alissa Davis as a plaintiff, and may add claims or allegations concerning Davis, if Davis seeks to join the action without a lawyer.
The court clarified that the amended complaint may not substitute or rename John Doe #1 or John Doe #2 because those defendants had already been dismissed. The order is procedural: it addresses defendant identification and amendment of the complaint, not whether Abdul-Aleem’s Eighth or Fourteenth Amendment claims are legally valid.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.