Medina v. New York City Department of Corrections
- Katherine Failla
- 1:20-cv-03985
- U.S. District Court · Southern District of New York
- 5
In Medina v. New York City Department of Correction, Judge Failla dismissed claims against two defendants during prisoner screening while allowing claims against two others to continue.
The order dismissed Anthony Medina’s claims against the New York City Department of Correction and the New York State Division of Parole. Claims against the City of New York and Warden Kisa Smalls were not dismissed in this order.
What happened
Anthony Medina, who was incarcerated at the North Infirmary Command on Rikers Island, brought this lawsuit without a lawyer under a federal civil-rights law, alleging constitutional violations. The court had allowed him to proceed without paying fees in advance.
The court dismissed Medina’s claims against the New York City Department of Correction because a New York City agency cannot be sued as a separate entity. It also dismissed his claims against the New York State Division of Parole because state immunity generally protects the state and its agencies from federal lawsuits, and the court found no waiver or congressional exception.
The order did not dismiss the claims against the City of New York or Warden Kisa Smalls. Judge Katherine Polk Failla requested that those defendants waive formal service of the lawsuit and denied fee-free status for any appeal, finding that an appeal would not be taken in good faith.
The detailed version
- Medina v. New York City Department of Corrections · No. 1:20-cv-03985
- Katherine Failla
- June 10, 2020
Background
Anthony Medina, who was incarcerated at the North Infirmary Command on Rikers Island, filed a civil-rights lawsuit under 42 U.S.C. § 1983 without a lawyer. He alleged that the defendants violated his constitutional rights. The court had granted permission to proceed without paying filing fees in advance.
Because Medina was a prisoner seeking relief from governmental defendants, the court screened his complaint under the Prison Litigation Reform Act. 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 explained that it must read filings by people without lawyers generously, but the complaint still must provide enough facts to make a claim plausible.
Claims Against the Department of Correction
The court dismissed Medina’s claims against the New York City Department of Correction. It held that a City agency is not a separate entity that can be sued under the applicable New York City law.
Claims Against the New York State Division of Parole
The court also dismissed Medina’s claims against the New York State Division of Parole. The court explained that the Eleventh Amendment generally prevents states, their agents, and their instrumentalities from being sued in federal court. It found that New York had not waived this immunity and that Congress had not removed it when it enacted Section 1983. The court therefore concluded that the claims were barred by state immunity.
Claims Against the City and Warden Smalls
The order did not dismiss the claims against the City of New York or Warden Kisa Smalls. Instead, the court requested that they waive formal service of the summons. The Clerk was directed to notify the New York City Department of Correction and the New York City Law Department and to mail Medina a copy of the order and an information package.
Disposition
The court dismissed Medina’s claims against the Department of Correction and the New York State Division of Parole. It requested waiver of service from the City of New York and Warden Smalls. The court also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. Judge Katherine Polk Failla signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.