Shantik Smith v. City of New York
- Katherine Failla
- 1:25-cv-01551
- U.S. District Court · Southern District of New York
- 17
Smith v. City of New York: Judge Failla added unidentified correction officers as defendants and ordered their identification; the order did not decide the underlying claims.
Shantik Smith, the City of New York, the five unidentified Department of Correction officers added as defendants, and the New York City Law Department, which must provide identifying and service information.
What happened
In Shantik Smith v. City of New York, Shantik Smith, representing himself, alleged that New York City violated his Muslim religious practices while he was detained at two facilities on Rikers Island. He described a public strip search, limits on Muslim services and Ramadan meals, and the absence of an imam.
Smith told the court that he also wanted to sue individual Department of Correction officers whose names he did not know. The court added five John and Jane Doe correction officers as defendants and ordered the New York City Law Department to identify them and provide service information.
Judge Katherine Polk Failla did not decide whether Smith’s allegations were legally valid. She required the Law Department to respond within 60 days and Smith to file a replacement amended complaint within 30 days after receiving the information; the court will screen that complaint later.
The detailed version
- Shantik Smith v. City of New York · No. 1:25-cv-01551
- Katherine Failla
- Sept. 26, 2025
Background
Shantik Smith, who was incarcerated at West Facility on Rikers Island and was representing himself, brought a claim under 42 U.S.C. § 1983 against the City of New York. He alleged that officials violated his right to practice Islam during detention at West Facility and the Eric M. Taylor Center.
Smith alleged that he was subjected to a public strip search in front of other detainees, contrary to his religious belief that men may not stand naked in front of other men. He also alleged that during Ramadan in 2024 he could not attend Muslim services and did not receive a double portion of food or a packaged meal for the next morning, causing him to go hungry. He further alleged that rabbis, chaplains, and priests were available at West Facility but that Muslim detainees were not provided an imam. The opinion noted inconsistencies in the dates stated in the complaint; the relevant events generally appeared to fall between March 7 and April 10, 2024.
Adding and identifying defendants
During a September 24, 2025 telephone conference, Smith stated that he intended to sue individual New York City Department of Correction officers. Because he was representing himself and the officers’ identities were not known, the court directed the Clerk of Court to add “John and Jane Doe Correction Officers 1-5” as defendants under Federal Rule of Civil Procedure 21.
The court also directed the Clerk to notify the New York City Law Department and the Department of Correction. Relying on the procedure that allows a court to help a self-represented litigant identify an unknown defendant, the court directed the Law Department to determine the identity and badge number of each officer Smith sought to sue and the address where each could be served. The Law Department must provide that information to Smith and the court within 60 days of the order.
Smith must file an amended complaint naming the identified defendants within 30 days after receiving the information. The amended complaint will replace, rather than supplement, the original complaint. The court stated that it will screen the amended complaint and, if necessary, ask the newly identified defendants to waive formal service.
Reminder about the City’s potential liability
The court reminded Smith that a municipality generally cannot be held liable under § 1983 merely because one of its employees allegedly acted unlawfully. To pursue a claim against the City, Smith must plead and prove that an official policy or custom caused the alleged denial of a constitutional right. The order did not decide whether Smith satisfied that requirement.
Disposition and effect
The court directed the Clerk to add the five Doe correction officers, directed the Law Department to provide identification and service information, and directed the Clerk to mail the order to Smith. It also informed Smith about a private organization that may provide limited legal assistance to self-represented litigants. The order did not decide the merits of Smith’s religious-practice allegations or dismiss the case.
Read the full 17-page opinion on CourtListener, the free public archive maintained by the Free Law Project.