Middleton v. BAYNER

Background

Natalia Middleton filed the action without a lawyer and was allowed to proceed without paying filing fees in advance. She alleged that, on June 5, 2024, her mother called emergency medical services after trying to prevent Middleton from leaving their residence. At Montefiore Hospital, Middleton alleged that a male nurse required her to sit in a medical bed, that a group of men forced her into a room, that her clothing was removed, and that she was injected with a sedative. She alleged that she was involuntarily committed for nine days.

Middleton claimed that Montefiore Hospital violated her due-process rights by failing to conduct a required confirmation examination on time and by misdiagnosing her, which led to improper treatment. She sought money damages and an order requiring Montefiore to implement stricter protocols for diagnosing and treating psychiatric patients. The defendants named in the complaint were Jessica Bayner, identified as a psychiatrist; Teresa Lebron-Correa, identified as a nurse practitioner; and David M. Klahr, identified as a doctor.

Federal claims

The court construed Middleton’s constitutional allegations as claims under 42 U.S.C. § 1983. To state such a claim, a plaintiff must allege both a violation of a constitutional or federal-law right and action by a person acting under state authority.

The court held that a private hospital and its staff are not state actors when they involuntarily commit someone for psychiatric care or medicate that person. Because Middleton alleged that the defendants were Montefiore employees and the court treated Montefiore as a private party, it dismissed all of her § 1983 claims for failure to state a claim on which relief could be granted.

State-law claims

The court also understood the complaint to assert possible state-law claims under supplemental jurisdiction, which is the federal court’s authority to hear related state-law claims. After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims Middleton may have asserted.

Leave to amend and disposition

Because Middleton was representing herself, the court granted her 30 days to file an amended complaint to try to correct the deficiencies. The order states that if she does not file an amended complaint within that period, the clerk will be directed to enter a judgment dismissing the action. The court directed the clerk to terminate the motion to compel release of records and to amend the complaint, and to keep the matter open on the docket until a civil judgment is entered.

In NATALIA MIDDLETON v. JESSICA BAYNER; TERESA LEBRON-CORREA; DR. DAVID KLAHR, Judge Louis L. Stanton dismissed the action with 30 days’ leave to replead; the order did not enter the later judgment described as contingent on failure to amend.