Rodriguez v. Williams
Jose A. Rodriguez v. Morton Williams; Morton Williams, Owner; Francisco – Last Name Unknown, Security Guard; Unknown Manager on Duty on 4-26-25 at 8PM
- Kimba Wood
- 1:25-cv-03775
- U.S. District Court · Southern District of New York
- 5
In Rodriguez v. Morton Williams, Judge Wood dismissed Rodriguez’s amended federal claims because private defendants were not state actors and declined state-law claims.
Jose A. Rodriguez’s federal claims were dismissed because he did not allege that the private store defendants acted for the government. His possible state-law claims were not decided in federal court, and the court denied another opportunity to amend. The court also denied permission to proceed without paying the filing fee for an appeal.
What happened
In Jose A. Rodriguez v. Morton Williams, Rodriguez said a grocery store’s security guard detained him, accused him of shoplifting, and used excessive force while searching his bag. He also alleged emotional distress and public defamation.
The court dismissed the federal constitutional claims because Rodriguez did not allege that the store, its owner, manager, or security guard acted for the government. The court declined to hear any state-law claims, including emotional-distress and defamation claims, and denied another opportunity to amend.
Judge Kimba M. Wood directed the Clerk to enter judgment. The court also denied fee-waiver status for any appeal after finding that an appeal would not be taken in good faith.
The detailed version
- Rodriguez v. Williams · No. 1:25-cv-03775
- Kimba Wood
- Sept. 3, 2025
Background
Jose A. Rodriguez filed the case without a lawyer and with permission to proceed without paying the filing fee. The court had dismissed his original complaint on June 25, 2025, but allowed him to file an amended complaint addressing the pleading’s deficiencies. Rodriguez filed the amended complaint on July 21, 2025.
Rodriguez alleged that on April 26, 2025, he was detained and accused of shoplifting at a Morton Williams store in the Bronx. He alleged that the store’s “unlicensed security guard” lacked probable cause to believe he was shoplifting and used excessive force to search his bag. After Rodriguez provided proof that he had paid for the items at another store, the items were returned. He also alleged severe emotional distress and that Defendants called him a thief in public.
Federal claims
The court treated Rodriguez’s false-arrest and excessive-force allegations as claims under 42 U.S.C. § 1983, a statute that permits claims for violations of federal rights by persons acting for the state. The court explained that private parties generally are not liable under Section 1983 and that private security guards generally are not state actors. Rodriguez did not allege that Morton Williams, its owner, its manager, or the security guard worked for a state or other government body. He also did not allege facts suggesting that the guard had been appointed as a New York City Police Department “special patrolman,” a category that can have police powers.
The court therefore dismissed the action for failure to state a claim on which relief may be granted under 28 U.S.C. § 1915(e)(2)(B)(ii), the statute governing dismissal of certain claims filed without paying the filing fee.
State-law claims and jurisdiction
Rodriguez also appeared to assert state-law claims for intentional infliction of emotional distress and defamation, along with any other tort claims he may have been asserting. The court concluded that it lacked diversity jurisdiction because Rodriguez did not allege facts showing that the parties were citizens of different states or that the claims exceeded the $75,000 jurisdictional minimum.
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—instead of deciding those claims. The order stated that nothing in it limited Rodriguez’s ability to seek any relief to which he may be entitled in state court.
Further amendment and disposition
The court denied further leave to amend because Rodriguez had already been given an opportunity to amend and the amended complaint did not suggest that another amendment could cure the defects. The court dismissed the action, directed the Clerk to enter judgment, and certified that any appeal would not be taken in good faith. It therefore denied permission to proceed without paying the filing fee for an appeal. The order did not state that the dismissal was with or without prejudice.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.