Sanchez v. Miller

Background

Matthew Sanchez and Tianna S. Sanchez filed this action without lawyers, alleging that defendants violated their federal rights. The allegations concerned visits by the Sullivan County Sheriff’s Office, Matthew Sanchez’s September 7, 2019 arrest, the use of pepper spray against both plaintiffs, force used against Tianna Sanchez during the arrest, comments allegedly made at the police station, and events in proceedings before Judges T. Martini, Richard Clarino, and Martin Miller.

The plaintiffs named the State of New York, the New York State Police, local and state law-enforcement personnel, the three judges, and Assistant District Attorney Brian P. Conaty. They requested an immediate stay, an order restricting state officials, cancellation of summonses and charges, removal of a case from the Town of Thompson, release, and monetary damages.

Screening and pleading requirements

Because the plaintiffs had been allowed to proceed without prepaying filing fees, the court reviewed the complaint under the federal statute governing screening of such complaints. The court said the 72-page, single-spaced complaint did not meet Rule 8’s requirement of a short and plain statement showing entitlement to relief. The court directed that any amended complaint be limited to 25 pages and contain clear facts explaining what each defendant did, when and where the events occurred, how the conduct violated the plaintiffs’ rights, their injuries, and the relief sought.

Claims dismissed or barred

The court dismissed the plaintiffs’ claims under 42 U.S.C. § 1983 against the State of New York and the New York State Police because the Eleventh Amendment generally protects states and state instrumentalities from suits for damages in federal court, and the court said New York had not waived that protection and Congress had not removed it for these claims.

The court also dismissed the § 1983 claims against Judges Martini, Clarino, and Miller under judicial immunity because the allegations concerned actions taken in their judicial roles. The court explained that judges generally cannot be sued for damages for judicial acts, even when bad faith or malice is alleged. The court further stated that any claims against Assistant District Attorney Brian P. Conaty based on prosecutorial duties were barred by prosecutorial immunity and were frivolous; the complaint did not appear to include factual allegations about him.

The court declined to stop any pending state criminal proceedings because the complaint did not clearly identify the proceedings or show bad faith, harassment, or serious and immediate irreparable harm. Under the rule commonly called Younger abstention, a federal court generally may not interfere with ongoing state criminal proceedings. The court also stated that the Rooker-Feldman doctrine prevents a federal district court from reviewing and rejecting final state-court judgments.

Claims allowed to be amended

The court read the complaint liberally as asserting § 1983 claims for false arrest, malicious prosecution, and excessive force, and granted leave to amend only those claims.

For false arrest, the court said Matthew Sanchez needed to identify the officers who allegedly arrested him and allege facts showing that the arrest lacked probable cause. If the arrest was based on a warrant, he needed to allege facts suggesting that the warrant was facially invalid or obtained through fraud, perjury, or falsified evidence. The court noted that conclusory statements that an arrest was illegal or unlawful were insufficient. It was unclear whether Tianna Sanchez also intended to assert false arrest, so any such claim would need facts specific to her. The court also explained that a damages claim inconsistent with a conviction may be barred unless the conviction or sentence has been reversed, expunged, invalidated, or otherwise called into question as described by the governing law.

For malicious prosecution, either plaintiff needed to allege facts showing that a defendant initiated or continued the prosecution without probable cause, acted with malice, and that the prosecution ended in that plaintiff’s favor. If there had been a conviction, the amended complaint would need to allege that it had been reversed or otherwise invalidated. The plaintiffs also had to identify the particular defendant personally involved in causing the alleged harm.

For excessive force, the plaintiffs were directed to restate their allegations that Sergeant Starner pepper-sprayed them and that officers used force against Tianna Sanchez while Matthew Sanchez was being arrested. They had to identify the officer who allegedly used force against Tianna Sanchez and allege facts showing that the force was unreasonable.

Disposition and deadline

Judge Colleen McMahon granted the plaintiffs leave to file an amended complaint within 60 days of the order. The amended complaint would replace, rather than supplement, the original complaint and could include only the permitted false-arrest, malicious-prosecution, and excessive-force claims. No summons would issue at that time. The court stated that if the plaintiffs did not comply within the deadline and could not show good cause, the court would dismiss the complaint for failure to state a claim.