Crowe v. Sheridan

Background

David Crowe appeared without a lawyer and sued under 42 U.S.C. § 1983, alleging violations of the First, Fourth, Fifth, and Fourteenth Amendments. He alleged that Timothy Sheridan, who provided security for Taylor Swift, falsely claimed to have been sent by the Federal Bureau of Investigation and gave police information about Crowe’s presence near Swift’s apartment. Crowe also alleged that police arrested him while he was begging, left his belongings on the street, failed to take him to Bellevue Hospital for frostbite, and arrested him in connection with an alleged restraining-order violation.

Crowe further alleged that he was institutionalized at Manhattan Psychiatric Center, was forced to take psychiatric medication, was denied prescribed tea and access to legal counsel, and did not receive adequate care for a broken foot. He also alleged that Google posted health information and references to him stalking Taylor Swift, but Google was not named as a defendant in this action. Crowe sought damages and jail time for the defendants.

Screening standard

Because Crowe was allowed to proceed without paying filing fees in advance, the court was required to screen the complaint. It had to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also said that, although pleadings filed by people without lawyers are read generously, they still must provide enough factual detail to make a claim plausible.

New York City Police Department

The court dismissed the claims against the NYPD because, under the New York City Charter, the agency cannot be sued in its own name. The court did not rule that every possible claim arising from Crowe’s arrests was legally invalid. Instead, it stated that Crowe could try to replead a false-arrest claim by naming one or more individual NYPD employees and alleging facts addressing whether the arrests were made without probable cause. Probable cause means facts that would lead a reasonably cautious person to believe that a crime had been committed by the person arrested.

Manhattan Psychiatric Center

The court dismissed the claims against Manhattan Psychiatric Center because it is part of the New York State Office of Mental Health and therefore is treated as an arm of the state. The court held that New York had not waived its constitutional immunity from this type of federal lawsuit, and Congress had not removed that immunity when it enacted Section 1983.

The court nevertheless explained the legal standard that could apply if Crowe amended his complaint to sue individual defendants over forced medication. Psychiatric patients generally have a protected liberty interest in avoiding unwanted antipsychotic medication. That interest may be overridden in limited circumstances, including when a patient presents a danger to himself or others or engages in dangerous or potentially destructive conduct in the institution. A professional’s decision is generally presumed valid unless it substantially departs from accepted professional judgment, practice, or standards.

Timothy Sheridan

The court dismissed the Section 1983 claims against Sheridan. Section 1983 generally requires a plaintiff to show both a violation of a federal right and conduct by someone acting for the government. The court said Sheridan appeared to be a private party and that Crowe had not alleged facts showing Sheridan had been appointed as a special patrolman or otherwise acted under government authority. The court also stated that giving false information to police, without more, generally does not make a private person a government actor for Section 1983 purposes.

State-law claims and leave to amend

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the federal court’s discretionary authority to hear related state-law claims. The court granted Crowe 60 days to file an amended complaint. Any amended complaint must replace the original complaint rather than supplement it, and Crowe must repeat any facts or claims he wants to preserve. He must identify the individuals allegedly involved, describe their conduct and the relevant dates and locations, describe his injuries, and state the relief sought. If he does not file an amended complaint, the court stated that it will enter judgment dismissing the complaint.