Morgan

Background

Troy Morgan, who is detained at West Facility on Rikers Island, filed this action without a lawyer under 42 U.S.C. § 1983. He alleges that conditions of confinement at the facility—including sanitation, plumbing, and mail-service conditions—violate his federal constitutional rights. The court had previously granted Morgan permission to proceed without prepaying filing fees.

Morgan’s complaint did not include a caption identifying a defendant. The Clerk therefore opened the case without a formally designated opposing party.

Court’s action

The court relied on Federal Rule of Civil Procedure 21, which allows a court to add or remove a party at any time on appropriate terms. The court explained that this rule gives courts discretion to shape a case to promote efficiency and justice, including adding as a defendant an entity mentioned in the body of a complaint as involved in the alleged events.

The court found that West Facility is operated by the New York City Department of Correction. Considering Morgan’s self-represented status and his clear intention to assert claims against the City of New York, the court treated the complaint as asserting claims against the City.

Disposition

The court directed the Clerk to add the City of New York as a defendant under Rule 21 and to electronically notify the New York City Department of Correction and the New York City Law Department. The court requested that the City waive service of summons and stated that adding the City was without prejudice to any defenses the City may assert. The Clerk was also directed to mail Morgan a copy of the order and an information package.

This order added a party; it did not decide whether Morgan’s constitutional claims are legally valid or whether the alleged conditions violated his rights.