Coleman v. City of New York

Background

Brian Coleman sued the City of New York, the New York City Police Department, named and unnamed police officers, Dollar Tree Store 4925, Dollar Tree Stores, Inc., Dollar Tree Store Management Inc., and named and unnamed Dollar Tree security guards. He alleged that the defendants violated his constitutional and state-law rights during and after his December 18, 2015 arrest at Dollar Tree Store 4925.

According to the amended complaint, Dollar Tree security guards accused Coleman of shoplifting, detained him in a store security office, and called the police. Police officers searched Coleman but found no contraband or store merchandise. Coleman alleged that the police reviewed surveillance video, questioned him, and nonetheless arrested him after the security guards continued to demand an arrest. He further alleged that police held him for approximately 24 hours, withheld medical treatment and basic necessities, confiscated personal property, and that the charges were later dismissed.

Coleman asserted claims including false arrest, imprisonment, malicious prosecution, unlawful search and seizure, excessive force, inadequate conditions of confinement, denial of a fair trial, cruel and unusual punishment, and conspiracy to interfere with civil rights. The Dollar Tree defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), which uses the same pleading standard as a motion to dismiss for failure to state a claim.

Rulings on the Federal Claims

The court held that Coleman did not plausibly allege that the Dollar Tree defendants were state actors or acted under color of state law. A private party generally can be sued under 42 U.S.C. § 1983 only when the party acted as a state actor or participated in conduct sufficiently connected to the state. The court said Coleman did not allege that the security guards had been designated as special patrolmen or received comparable authority under state law.

The court also held that Coleman did not plausibly allege joint action between the security guards and police. Although the complaint alleged that the guards insisted on an arrest, the police questioned Coleman, brought his family into the security office, searched him, and reviewed surveillance video. The court concluded that these allegations did not show that the police simply substituted the guards’ judgment for their own.

The court therefore dismissed against the Dollar Tree defendants the claims identified in the opinion as the first, third, fourth, fifth, sixth, eighth, and ninth causes of action, insofar as they alleged violations of § 1983 or the United States Constitution. The court separately dismissed Coleman’s claim under 42 U.S.C. § 1985 because the amended complaint did not allege facts showing racial or other class-based discriminatory intent. The conclusion refers to the tenth and eleventh causes of action for this ruling, although the earlier procedural history lists ten causes of action.

State-Law Claims

The court held that Coleman’s state-law false-arrest, illegal-imprisonment, and malicious-prosecution claims were barred by New York’s one-year statute of limitations. Coleman was arrested on December 18, 2015, released the following day, and filed the action on December 17, 2018. The court dismissed the state-law claims identified as the first and sixth causes of action against the Dollar Tree defendants.

Disposition

The court granted the Dollar Tree defendants’ motion for judgment on the pleadings. It directed the Clerk to terminate the motions at Docket Entries 18 and 24 and dismiss Dollar Tree Store 4925, Dollar Tree Stores, Inc., Dollar Tree Store Management Inc., Alexander Etseyotse, and Security Guards John and Jane Doe #1-10 from the action. The claims against the City of New York and the police officer defendants remained pending.