Paloma v. New York City Department of Corrections

Background

Miriahm Paloma brought a pro se action under 42 U.S.C. § 1983. She was detained at the Rose M. Singer Center. Paloma alleged that on February 13, 2020, Correction Officer Easterling sat near a dorm window facing Paloma’s bed, talked to herself, used a flashlight every 15 minutes, and watched Paloma walk back and forth to the bathroom. Paloma alleged that she was not on suicide watch and that she suffered trouble sleeping and blurred vision. She requested $122,525,018.12 and other relief.

The court had previously allowed Paloma to proceed without prepaying the filing fee. Because Paloma was a prisoner seeking relief against governmental defendants, the court screened the complaint under the Prison Litigation Reform Act. The court explained that it must dismiss claims that are frivolous, malicious, fail to state a claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. It also explained that, although filings by people without lawyers are read generously, they must still provide enough factual detail to make a claim plausible.

Claims Against the Department of Correction

The court dismissed Paloma’s claims against the New York City Department of Correction. Relying on New York City Charter § 396 and cited cases, the court held that a New York City agency is not a separate entity that can be sued.

Conditions-of-Confinement Claim

The court interpreted Paloma’s allegations as asserting a conditions-of-confinement claim under the Fourteenth Amendment. The court explained that a condition of pretrial detention may be unconstitutional if it amounts to punishment. A restriction that is reasonably related to a legitimate governmental objective generally does not amount to punishment. If the condition is not punitive, the plaintiff must show both an objectively serious deprivation and deliberate indifference. Deliberate indifference requires facts showing that the officer intentionally imposed the condition or recklessly failed to take reasonable care despite knowing, or having reason to know, that it created an excessive risk to health or safety.

The court found Paloma’s allegations insufficiently clear at the screening stage. Although she alleged that Easterling watched her and used a flashlight and that Paloma was not on suicide watch, the allegations did not clearly show that Easterling’s actions were unrelated to a legitimate government objective. They also did not clearly show that Easterling knew, or should have known, that her actions posed a serious risk to Paloma’s health or safety and disregarded that risk.

Order to Amend

The court granted Paloma leave to file an amended complaint within 60 days. The amended complaint must provide a short and plain statement of the facts supporting each claim, identify relevant people and their titles, describe what each defendant did or failed to do, provide dates and locations, explain the alleged rights violations and injuries, and state the requested relief. The amended complaint will replace rather than supplement the original complaint. The court stated that if Paloma did not comply within the allowed time and could not show good cause, the complaint would be dismissed for failure to state a claim. No summons was issued at that time.