Medina v. City of New York

Background

Leonardo Medina filed the action without a lawyer while he was held in the Rose M. Singer Enhanced Supervised Housing Unit on Rikers Island. The court had already allowed him to proceed without prepaying filing fees. He sued the City of New York, Correction Captain Washington, Correction Officers Rucker and Jones, and two unidentified intake staff members at the Otis Bantum Correctional Center. The court understood the complaint to assert claims under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state law for violations of federal rights, as well as state-law claims.

Medina alleged that on August 4, 8, 11, and 14, 2024, staff moved him in violation of facility security rules despite a known risk of harm. He alleged that he was denied food and trapped in an unsafe environment while urine, feces, and chemical agents were thrown through his cell slot. He also alleged that staff failed to secure the area before moving him, and that he suffered slashings and a disciplinary infraction. He further alleged that staff ignored his inquiries, denied him a fair disciplinary hearing and a written disposition, and harassed him.

Screening and Rulings

The court screened the complaint under federal laws requiring review of prisoner complaints seeking relief from governmental entities or employees. It applied the rule that a complaint must include enough factual detail to make a claim plausible, while giving special consideration to complaints filed without a lawyer.

Claims against the City

The court dismissed Medina’s § 1983 claims against the City of New York because he did not allege facts showing that a City policy, custom, or practice caused a violation of his federal constitutional rights. The court granted him leave to replead those claims in an amended complaint.

Claims against individual defendants

The court dismissed Medina’s § 1983 claims against the individual defendants because he did not allege facts showing each person’s direct and personal involvement in the alleged constitutional violations. The court granted him leave to replead claims against those defendants or other individual Otis Bantum Correctional Center staff members, identifying each person and describing that person’s direct involvement.

Conditions-of-confinement claims

The court treated Medina’s allegations about food, safety, sanitation, exposure to bodily waste and chemical agents, and the alleged slashings as conditions-of-confinement claims. It explained that the required legal standard could depend on whether Medina was a pretrial detainee, convicted prisoner, or parolee at the time. Regardless of his status, however, the court found that he had not alleged facts showing that any individual defendant acted with the required deliberate indifference. The court dismissed these § 1983 claims for failure to state a claim and granted leave to replead them.

Leave to amend and other rulings

The court granted Medina 60 days to file an amended complaint. The amended complaint must replace the original complaint rather than supplement it, identify the people directly involved, describe what each person did or failed to do, provide relevant dates and locations, describe injuries, and state the requested relief. Medina may use “John Doe” or “Jane Doe” for an unidentified defendant, but the court stated that doing so does not pause the three-year limitations period for § 1983 claims.

The court stated that if Medina does not timely amend and cannot show good cause, it will dismiss his § 1983 claims and decline to consider his state-law claims under its supplemental jurisdiction. No summonses will issue at this time. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.