Coleman v. The State of Officer John Doe

Background

David Coleman, who was incarcerated at Gouverneur Correctional Facility, filed this pro se action under 42 U.S.C. § 1983. He alleged that the New York City Police Department arrested him on approximately April 28, 2017, for allegedly steering a drug purchase, although he said he did not know about the suspects’ involvement. He alleged that he was arraigned the next day, bail was set at $1,000, and the criminal case was dismissed on September 19, 2017. He sought a declaration that the defendants violated the Constitution and $2 million in compensatory damages.

The caption named the State of New York Police Department and the City of New York. In the body of the order, the court described the defendants as the State of New York and the City of New York.

Proceeding Without Prepaying the Filing Fee

Because Coleman was a prisoner seeking to proceed without prepaying the filing fee, the court reviewed whether 28 U.S.C. § 1915(g), commonly called the “three-strikes” rule, barred that status. The court examined several of Coleman’s earlier cases and concluded that he did not have three qualifying dismissals when he filed this action. The court therefore granted his application to proceed without prepaying the full filing fee.

False-Arrest Claim

The court explained that a federal false-arrest claim under § 1983 generally requires facts showing that the confinement was not legally justified. Probable cause to arrest is a complete defense to such a claim.

The court held that Coleman’s allegation that the criminal charges were later dismissed was not enough to show that the arrest was unlawful. He did not allege, for example, that he was arrested without a warrant. He also did not name the individual officer who arrested him, even though a § 1983 claim requires facts showing each defendant’s direct and personal involvement in the alleged constitutional violation. The court therefore found the allegations insufficient to state a false-arrest claim, but granted Coleman leave to replead it in an amended complaint.

Claims Against the City of New York

The court explained that a city cannot be held liable under § 1983 merely because one of its employees allegedly committed wrongdoing. A plaintiff must allege facts showing that a city policy, custom, or practice caused the constitutional violation.

The court found that Coleman had not alleged facts showing that a policy, custom, or practice of the City of New York caused a violation of his rights. The order instructed him that, if he named the City in an amended complaint, he would need to provide those facts.

Claims Against New York State

The court held that the State of New York was immune from suit in federal court under the Eleventh Amendment. It stated that New York had not waived that immunity and that Congress had not removed it when it enacted § 1983. The court therefore dismissed Coleman’s § 1983 claims against the State of New York without leave to replead.

Leave to Amend and Disposition

The court granted Coleman leave to file an amended complaint within 60 days. The amended complaint had to identify the individuals allegedly involved, describe what each defendant did or failed to do, provide relevant dates and locations, explain how the conduct violated his rights, describe his injuries, and state the relief sought. The court allowed him to use “John Doe” or “Jane Doe” for an unidentified defendant, but warned that doing so would not stop the three-year limitations period.

The amended complaint would completely replace the original complaint, rather than add to it. The court directed Coleman to submit it to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 20-CV-2146 (LLS). No summons would issue at that time. Judge Louis L. Stanton warned that if Coleman did not timely amend and could not show good cause, the complaint would be dismissed for failure to state a claim.