Hill v. The City of New York

Background

Ronald Hill, who was incarcerated at the time, brought this case without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims for violations of constitutional rights by state or local government actors. Hill alleged that on August 16, 2019, he was being transported by bus from the Manhattan courthouse to the Robert N. Davoren Center on Rikers Island. He said the bus was speeding, hit another vehicle while turning, and caused him to hit his back and head against the bus wall.

Hill alleged that he went to the facility’s clinic, where he was prescribed muscle-pain lotion and pain medication and was told he would receive follow-up care. He said he was never called back, continued to experience back stiffness, muscle tension, and knee pain, and later signed up for sick call but received no relief. He sought damages from the City of New York, the New York City Department of Correction, two unidentified correction officers, New York City Health + Hospitals Corporation, and unidentified medical defendants.

Screening standards

Because Hill was allowed to proceed without prepaying the filing fee, the court screened the complaint under federal statutes requiring dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, seek relief from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also said that it must read complaints filed without a lawyer liberally and interpret them to raise the strongest claims suggested by the allegations.

Department of Correction

The court dismissed Hill’s claims against the Department of Correction. It held that the Department is a City agency that cannot be sued in its own name. The court instructed Hill not to name the Department in any amended complaint because claims against it must instead be brought against the City of New York.

Negligent driving

The court dismissed Hill’s claim that the bus driver’s negligent driving violated § 1983. It held that a public official’s negligent act, even if it causes injury, does not violate the Constitution. The court characterized allegations that an official drove too fast as negligence rather than a constitutional violation.

Medical-care allegations

The court considered Hill’s allegations under both the Eighth Amendment standard for convicted prisoners and the Fourteenth Amendment standard for pretrial detainees because the complaint did not make clear which status applied when he sought medical care. Both standards require allegations showing an objectively serious medical need. The legal standard for the official’s state of mind differs: an Eighth Amendment claim generally requires awareness of a substantial risk of serious harm, while a Fourteenth Amendment claim may be based on an official’s failure to act reasonably after the official should have known of an excessive risk.

The court found that Hill had not alleged enough facts to show an objectively serious medical need. He did not allege that his condition was urgent, that the delay caused extreme pain or worsening of his condition, or how long he waited for follow-up care. The court also found that the complaint was unclear about whether Hill did not receive the prescribed medication or was instead challenging the delay in a follow-up visit.

The court further held that Hill did not explain what either unidentified correction officer personally did or failed to do, or whether either officer was involved in his medical care. As to the City and New York City Health + Hospitals Corporation, the court held that Hill did not allege a municipal policy, custom, or practice that caused a violation of his rights. The court therefore found that Hill failed to state medical-care claims against those defendants on the allegations then presented.

Leave to amend and disposition

The court granted Hill leave to file an amended complaint within sixty days. The amended complaint must replace, rather than supplement, the original complaint and must include every fact and claim Hill wants to maintain. The court directed him to identify relevant people and their titles, describe what each defendant did or failed to do, provide dates and locations, explain how his rights were violated, describe his injuries, and state the relief requested. The court stated that no summons would issue at that time and that failure to comply, absent good cause, would result in dismissal for failure to state a claim.

Judge Colleen McMahon also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.