Darryl A. Johnson v. Rikers Island OBCC, et al.

Background

Darryl A. Johnson, who was incarcerated at Wallkill Correctional Facility when the opinion was issued, brought the action without a lawyer. He alleged that, while detained at the Otis Bantum Correctional Center on Rikers Island, he was denied recreation for eight consecutive days, from March 4 through March 11, 2025. He sought damages for each day and invoked the New York State Constitution. The defendants were “Rikers Island OBCC,” the City of New York, and John Doe Correction Officers #1-#4.

The court had previously allowed Johnson to proceed without prepaying the filing fee. Because he was proceeding that way and sought relief against governmental defendants, the court screened the complaint under the Prison Litigation Reform Act.

Rikers Island OBCC

The court dismissed the claims against “Rikers Island OBCC” because the facility, like the New York City Department of Correction facilities it operates, does not have the capacity to sue or be sued in its own name. The court stated that claims involving the facility must instead be brought against the City of New York, which Johnson had already named.

Jurisdiction and federal constitutional claim

The court explained that federal district courts generally have jurisdiction over federal-law claims or certain disputes between citizens of different states involving more than $75,000. Johnson relied on the New York State Constitution, so his claims did not present a federal question on that basis. The court also stated that the allegations did not satisfy diversity jurisdiction because Johnson and some or all defendants were citizens of New York and the amount-in-controversy requirement was not met.

Because the recreation allegations might be understood as asserting a claim under 42 U.S.C. § 1983 for unconstitutional conditions of confinement, the court construed the complaint to include that federal claim. For a pretrial detainee’s conditions-of-confinement claim, the court explained that the alleged condition must pose an objectively unreasonable risk of serious harm, and the correction official must have intentionally imposed the condition or recklessly failed to address a known excessive risk.

The court recognized a constitutional right to a meaningful opportunity for physical exercise. It noted, however, that the complaint did not say whether Johnson had other out-of-cell activities or could exercise in his cell, and did not explain the reason given for denying recreation. Based on the allegations and decisions involving relatively brief exercise restrictions, the court stated that eight consecutive days without recreation appeared, as a matter of law, not to constitute an objectively serious risk of harm sufficient to implicate the Constitution.

City of New York

The court explained that a municipality cannot be held liable under § 1983 merely because one of its employees allegedly committed wrongdoing. A plaintiff must allege a municipal policy, custom, or practice that caused the constitutional violation. The court found that Johnson did not allege that the denial of recreation resulted from any City policy, custom, or practice. The allegations therefore did not state a § 1983 claim against the City even assuming the recreation denial violated the Constitution.

John Doe defendants

The court also dismissed the claims against John Doe Correction Officers #1-#4 for failure to state a claim. Johnson did not allege what any particular unidentified officer did or failed to do, so the complaint did not show the officers’ direct and personal involvement in the alleged violation.

State-law claims and leave to replead

After dismissing the federal claims over which it had original jurisdiction, the court declined to exercise supplemental jurisdiction over Johnson’s New York State Constitution claims. Supplemental jurisdiction is the court’s authority to hear related state-law claims alongside federal claims.

Because Johnson was representing himself, the court granted him 30 days to file an amended complaint addressing the defects, although it said it was unclear what additional facts could support a claim. The court’s conclusion states that the complaint was dismissed with 30 days’ leave to replead. If Johnson does not amend within the permitted time, the Clerk will be directed to enter judgment dismissing the § 1983 claims for failure to state a claim and declining supplemental jurisdiction over the state-law claims. The opinion also notes that Johnson may voluntarily withdraw the case without prejudice.