Williams v. Green Haven C.F.

Background

Tearre Williams filed this action without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims against persons who violate constitutional rights under state law. He alleged that the defendants violated his rights while he was incarcerated at Green Haven Correctional Facility. He paid the filing fee.

The complaint named Green Haven Correctional Facility, an unidentified nurse practitioner, Lieutenants Perez and Hindsbeck, and Sergeant Cuello. Williams alleged that he was extracted, denied seizure and high-blood-pressure medication, assaulted by correctional officers, and called a racial slur. He alleged that the nurse practitioner discontinued his medication from January 6, 2025, to February 8, 2025, and that he suffered a seizure and headaches. He sought money damages and an order removing him from the Residential Rehabilitation Unit.

Screening and Rule 8

The court screened the prisoner complaint under the Prison Litigation Reform Act. That screening requires dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also explained that Rule 8 requires a short and plain statement showing why the plaintiff is entitled to relief.

The court ruled that Williams’s single-sentence allegations did not satisfy Rule 8. He did not provide factual context, including where or when the events occurred, what happened, or how his rights were violated. He also did not allege facts showing how Perez, Hindsbeck, or Cuello participated in the events.

Claims Against Green Haven

The court dismissed Williams’s Section 1983 claims against Green Haven Correctional Facility because the facility is not a “person” that can be sued under Section 1983.

Medical-Care Claims

The court treated the allegation that the nurse practitioner discontinued Williams’s medication as an attempt to bring a Section 1983 claim for constitutionally inadequate medical care under the Eighth Amendment. Such a claim requires facts showing both an objectively serious medical condition and deliberate indifference—meaning that the official knew about and disregarded a serious risk to the prisoner’s health.

The court assumed for purposes of the order that suffering a seizure and headaches without medication was objectively serious. But it found that Williams alleged only that the nurse practitioner discontinued his seizure medication for a month. He did not allege facts showing that the nurse practitioner knew of and disregarded a serious health risk or acted with the required state of mind. The court therefore granted Williams leave to replead this claim with additional facts.

Excessive-Force Claims

The allegation that Williams was “jump[ed]” by unidentified correctional officers suggested a possible Eighth Amendment excessive-force claim. Such a claim requires facts showing that the force was sufficiently serious and that the officers used it maliciously or sadistically to cause harm, rather than as a good-faith effort to maintain or restore discipline.

The court found that Williams’s bare allegation did not satisfy either part of that standard. It granted him leave to amend by naming the individual correctional officers and describing facts supporting the claim.

Leave to Amend and Disposition

The court granted Williams 60 days from the date of the order to file an amended complaint. The amended complaint must completely replace the original complaint, so Williams must repeat any facts or claims he wants the court to consider. He must identify each defendant in both the caption and the statement of claim, describe what each person did or failed to do, provide approximate dates and locations, describe his injuries, and state the relief he seeks. If he does not know a defendant’s name, he may use “John Doe” or “Jane Doe,” but the court stated that doing so does not pause the three-year limitations period.

Judge Louis L. Stanton ordered that Williams’s claims against Green Haven Correctional Facility be dismissed for failure to state a claim. He granted Williams leave to file an amended complaint within 60 days and stated that no summons would issue at that time. The order also states that if Williams does not timely amend and cannot show good cause for the failure, the complaint will be dismissed for failure to state a claim.