Johnson v. City of New York

Background

Glenn Johnson brought this action without a lawyer under 42 U.S.C. § 1983, a federal law that permits claims against state or local actors for violating constitutional rights. He sued the City of New York, the New York Police Department, and Detectives Jalin Bulding, Robert Rentas, and Bryan Leote.

The court had previously dismissed Johnson’s claims for false arrest, malicious prosecution, and municipal liability, while allowing him to amend his excessive-force claims. In his Second Amended Complaint, Johnson alleged that on September 7, 2016, while held at the 43rd Precinct, he argued with Detective Bulding. Johnson alleged that Bulding pulled him from a holding pen, causing his head and body to hit a wall, and that Bulding and two other detectives shoved him against the wall. He also alleged that the detectives put him in tight handcuffs, returned him to the holding pen, and refused his request to go to a hospital. He reported a forehead bump, head pain, bruises on both wrists, and numb wrists.

Defendants moved to dismiss. Johnson did not respond by the original deadline or by a later deadline set by the court, which had warned that it would treat the motion as unopposed. The court therefore treated the motion as unopposed, but it still applied the standards governing dismissal of a complaint for failing to state a legally sufficient claim. On that type of motion, the court generally accepts well-pleaded factual allegations as true and asks whether they plausibly support relief.

Discussion

Medical-care claim. The court understood Johnson to be asserting a claim that defendants were deliberately indifferent to his medical needs. The court held that this claim was time-barred. Civil-rights claims arising in New York generally have a three-year limitations period. The alleged incident occurred on September 7, 2016, so the claim became untimely after September 7, 2019. Although Johnson’s original complaint and first amended complaint were filed before that date, they did not allege a medical need requiring treatment, a request to go to the hospital, or a refusal of medical care. The court held that the new medical-care allegations in the Second Amended Complaint arose from facts not previously alleged and therefore did not relate back to the earlier pleadings.

In a footnote, the court added that the medical-care claim would also fail on the merits even if it were timely. It said that the alleged forehead bump, head pain, wrist bruises, and numb wrists were not sufficiently serious to satisfy the objective requirement of a deliberate-indifference claim.

Handcuffing claim. The court held that Johnson’s excessive-force claim based on tight handcuffing was not time-barred because the Second Amended Complaint made the earlier handcuffing allegations more specific. But the court dismissed the claim on the merits. It explained that an unreasonable-handcuffing claim generally requires an allegation that the handcuffs were unreasonably tight, that officers ignored complaints about the handcuffs, and that the plaintiff suffered a sufficiently serious wrist injury. The court found that bruising and numbness, without allegations of lasting pain, extended injury, medical treatment, or a painful position maintained for a long time, were insufficient. It therefore dismissed the unreasonable-handcuffing claim.

Removal from the holding cell. The court analyzed Johnson’s claim that officers used excessive force when pulling him from the holding cell and pushing him against the wall under the Fourteenth Amendment’s protection against objectively unreasonable force against a pretrial detainee. It held that the alleged force and injuries were minimal. Johnson alleged that he was pulled out for handcuffing, immediately returned to the cell, and suffered a forehead bump and head pain. The court concluded that these allegations, without additional facts, did not show more than a minimal use of force or an objectively unreasonable degree of force. The court also noted that the claim would not survive under either the Fourth or Fourteenth Amendment because Johnson’s status at the time was unclear.

Disposition

Judge Andrew L. Carter, Jr. granted defendants’ motion to dismiss. The court dismissed both the deliberate-indifference-to-medical-needs claim and the excessive-force claims, and directed the Clerk to close the case. The opinion does not state that the dismissal was with or without prejudice.