Allah v. Lamanna

Background

Anthem Be-Truth Allah, proceeding without a lawyer, sued Superintendent Jamie Lamanna and Deputy Superintendent of Security Anthony Russo. He asserted an Eighth Amendment claim under Section 1983, a federal civil-rights statute, alleging deliberate indifference to unsafe prison conditions.

Allah alleged that, on June 10, 2018, he was walking through a crowded landing and stairwell at Green Haven Correctional Facility when another incarcerated person, identified as Ortiz, was assaulted. Allah alleged that Ortiz either was pushed or tripped on wet stairs while trying to escape and then fell onto Allah’s right leg and ankle. Allah also alleged an injury to his left shoulder that required surgery in June 2019.

According to Allah, the stairwell and landing were a known and dangerous blind spot, and the defendants knew about the danger from unusual-incident reports and a history of assaults. He also alleged that there was inadequate security coverage and that posting a guard in the blind spot would have deterred assaults. In his opposition, however, Allah conceded that security was present in the stairwell when he was injured.

Motion and Legal Standards

The defendants moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. On such a motion, the court accepts well-pleaded factual allegations as true and draws reasonable inferences for the plaintiff, but it does not accept bare legal conclusions or unsupported statements.

For an Eighth Amendment unsafe-conditions claim, a plaintiff must plausibly allege both an objectively serious risk of harm and that the defendant acted with deliberate indifference—that is, knew of a substantial risk of serious harm and failed to take reasonable steps to address it. A Section 1983 claim also requires facts showing each government defendant’s personal involvement; supervisory status alone is not enough.

Court’s Analysis

The court held that the amended complaint did not satisfy the objective requirement. Although Allah described the stairwell as a dangerous blind spot, he did not specifically allege a similar earlier incident in that stairwell. The earlier incident mentioned in his opposition occurred at Green Haven nearly forty years earlier but not in the stairwell. The court stated that the injury resulted from Ortiz’s alleged assault and fall onto Allah, rather than from the stairwell or the failure to secure it, and concluded that the alleged conditions did not pose an unreasonable risk of serious harm to Allah’s health.

The court separately held that Allah had not adequately alleged the defendants’ personal involvement. The amended complaint did not identify when the alleged unusual-incident reports were written, what they said, or to whom they were sent. The court found no factual link between those reports and Lamanna or Russo beyond their supervisory positions. It therefore found no sufficient allegation that either defendant knew of the stairwell’s risk and chose to disregard it.

Because the court found no constitutional violation, it did not address the defendants’ qualified-immunity argument.

Leave to Amend and Disposition

The court considered whether Allah should receive another opportunity to amend. Allah had already amended his complaint after facing essentially the same dismissal arguments. The court concluded that the defects were substantive and that better pleading would not cure them, so another amendment would be futile.

Judge Vincent L. Briccetti granted the defendants’ motion to dismiss, directed the clerk to terminate the motion and close the case, and certified that any appeal would not be taken in good faith. The court therefore denied Allah permission to proceed without paying filing fees for an appeal.