Alexander Williams Jr. v. New York State, et al.
- Cathy Seibel
- 7:25-cv-02499
- U.S. District Court · Southern District of New York
- 2
Williams v. New York State: Judge Seibel denied a motion for preliminary injunction seeking corrective surgery for a left-foot bunion.
The ruling affects Alexander Williams Jr.’s request for an order requiring New York State to provide corrective surgery for his left-foot bunion; the court denied that request.
What happened
In Alexander Williams Jr. v. New York State, Alexander Williams Jr. asked the court to order New York State to provide corrective surgery for a bunion on his left foot.
Williams said he had been approved to see a specialist in May 2024, but he did not provide evidence that the referral was made or identify who made it. He also did not show that the bunion, rather than another foot problem, caused his pain, that the pain was severe enough to violate the Constitution, or that surgery was medically necessary.
The court denied the preliminary-injunction motion. Judge Cathy Seibel noted that the evidence showed a provider had recommended surgery for an injury to Williams’s right great toe, not his left-foot bunion, and that a later provider noted the bunion but recommended no action concerning it.
The detailed version
- Alexander Williams Jr. v. New York State, et al. · No. 7:25-cv-02499
- Cathy Seibel
- Sept. 12, 2025
Background
Alexander Williams Jr. moved for a preliminary injunction, which is a court order issued before final judgment, requiring New York State to provide corrective surgery for a bunion on his left foot. The Attorney General argued that the bunion was not mentioned in Williams’s Second Amended Complaint. The court rejected that argument, finding that the complaint mentioned the bunion.
Williams asserted that he had been approved to see a specialist for the bunion in May 2024 but that the consultation had not occurred. The court explained that, if those facts were established and the condition were sufficiently serious, a medical provider’s failure to follow up on a specialist referral could potentially support a claim of deliberate indifference to serious medical needs.
Court’s Analysis
The court found that Williams had not made the required showing for a preliminary injunction. He provided no evidence that the May 2024 referral was made or who made it. He also did not provide evidence that the left-foot bunion, rather than his other foot problems, caused his pain; that the pain was sufficiently extreme to amount to a constitutional violation; or that the requested surgery was medically indicated.
The court further noted that an exhibit showed a provider at Elmira Correctional Facility recommended surgery for an injury to Williams’s right great toe, not for the left-foot bunion. That provider recommended a podiatry evaluation at Williams’s next facility. A later exhibit showed that Williams received a mobility consultation at Auburn Correctional Facility in November 2023. The provider noted the bunion but recommended no action concerning it and instead recommended further evaluation of the right great toe.
Disposition
The court denied Williams’s motion for a preliminary injunction. Judge Cathy Seibel did not order the requested corrective surgery.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.