Williams, Jr. v. City of New York Department of Corrections

Background

Alexander Williams, Jr., proceeding without a lawyer, sued the City of New York Department of Correction, the City of New York, and NYC Health & Hospitals Corporation. The case concerned two incidents at the Manhattan Detention Complex on June 25 and July 17, 2019. Williams alleged that pepper spray was released near his housing unit, causing breathing problems and chest pain, and that correction officers delayed or failed to provide medical attention. He alleged that he had asthma and had to use his asthma pump more frequently after the incidents.

The Department of Correction removed the case from New York state court based on Williams’s allegations that his Fourteenth Amendment rights were violated through a civil-rights claim under 42 U.S.C. § 1983. Williams later amended the complaint to add the City and NYC Health & Hospitals Corporation. The defendants moved to dismiss for failure to state a claim, and Williams filed an unopposed motion for summary judgment. Williams also conceded that the Department of Correction should be dismissed because it could not be sued as a separate entity.

Fourteenth Amendment medical-care claims

The court treated Williams’s allegations as a claim that defendants were deliberately indifferent to his medical needs in violation of the Fourteenth Amendment. Because the court assumed Williams was a pretrial detainee, it applied the Fourteenth Amendment standard for such detainees.

To state this claim, Williams had to allege both an objectively serious medical condition and deliberate indifference to that condition. The court held that he had alleged neither requirement. For the June 25 incident, Williams alleged that he experienced respiratory distress and chest pain after pepper-spray exposure and received medical attention several hours later. The court found that he had not alleged that the delay caused his asthma to worsen into degeneration or extreme pain. For the July 17 incident, Williams alleged that he had trouble breathing, choked, banged on his cell door for at least 45 minutes, used the toilet bowl to obtain relief, and was later allowed to use his asthma pump but was not seen by medical staff. The court found that he had not alleged chronic and substantial pain or a significant effect on his daily activities.

The court also held that Williams had not alleged deliberate indifference. Regarding June 25, correction officers contacted medical staff several times, and the delay did not support an inference that they recklessly failed to act with reasonable care. Regarding July 17, Williams had been allowed to use his asthma pump, and the allegations did not show that correction officers intentionally deprived him of adequate care or recklessly failed to act with reasonable care. The court noted that a disagreement with the treatment received, without more, does not establish deliberate indifference.

Municipal liability

Williams also sought to hold the City and the other defendants liable under the municipal-liability doctrine associated with Monell. That doctrine requires a plaintiff to connect the alleged constitutional injury to an official municipal policy, practice, or custom rather than relying only on the employer-employee relationship.

The court first held that there could be no municipal liability because Williams had not adequately alleged an underlying constitutional violation. The court further held that, even if he had alleged such a violation, his allegations were insufficient to show a municipal policy or custom. His claim that the Department of Correction failed to provide medical care after pepper-spray deployments was based on the incidents alleged in his complaint and lacked supporting facts. The court also found that he had not identified a specific training or supervisory deficiency or facts showing that the City acted with deliberate indifference. The court explained that alleging that officers failed to follow an existing policy does not connect the injury to an unconstitutional policy or custom.

State-law claims and disposition

After dismissing all federal claims, the court declined to retain supplemental jurisdiction—the court’s authority to hear related state-law claims—and remanded Williams’s remaining New York state-law claims to the New York state court from which the case had been removed.

The court’s conclusion states that it GRANTS the defendants’ motion to dismiss Williams’s Section 1983 claims, REMANDS the remaining state-law claims to state court, and DISMISSES as moot Williams’s motion for summary judgment. The opinion’s opening paragraph instead states that Williams’s motion for summary judgment was DENIED. Judge Edgardo Ramos directed the Clerk to terminate the motions and close the case.