Leon Lucas v. Cynthia Brann

Background

Leon Lucas brought this civil-rights action under 42 U.S.C. § 1983 while incarcerated at the North Infirmary Command on Rikers Island. He alleged that the defendants held him in solitary confinement as a young adult. Lucas was proceeding without a lawyer. The court had granted his request to proceed without prepaying filing fees.

Screening standard

The court explained that it must screen a complaint filed by a person proceeding without prepaying fees or by a prisoner. Screening requires dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also stated that it must read filings by people without lawyers generously and interpret them to present the strongest claims they reasonably suggest.

New York City Department of Correction

The court dismissed Lucas’s claims against the New York City Department of Correction. It relied on the New York City Charter and related decisions holding that the correction department, as a city agency, is not an entity that can be sued in its own name. The court stated that claims against the department must instead be brought against the City of New York.

Cynthia Brann and service

The order directed the clerk to notify the New York City Department of Correction and the New York City Law Department. It requested that DOC Commissioner Cynthia Brann waive service of summons. The text does not state that Lucas’s claims against Brann were dismissed.

Disposition

The court dismissed Lucas’s claims against the New York City Department of Correction because the agency cannot be sued in the agency’s name. It directed the clerk to mail Lucas a copy of the order and an information package. The court certified that any appeal would not be taken in good faith and denied permission to appeal without prepaying fees.