Singleton v. The People of the State of New York

Background

Aaron Singleton, who was being held at the Anna M. Kross Center on Rikers Island, filed this action without a lawyer. He described the filing as a “criminal complaint” and alleged that defendants had conspired to commit crimes against him in connection with a criminal action in New York Supreme Court, Bronx County. He asserted federal and state constitutional claims and state-law injuries, seeking damages and the criminal prosecution of the defendants.

The defendants were the People of the State of New York; Bronx County Assistant District Attorneys Megan Leo and Allison Kline; the New York Supreme Court, Bronx County; Justice Ethan Greenberg; Singleton’s criminal defense attorney, Jesse Hoberman Kelly; the New York Defender Service, which the court said appeared to employ Kelly; and the New York City Department of Correction. The court construed Singleton’s federal constitutional claims as claims under 42 U.S.C. § 1983, a statute allowing claims for certain constitutional violations by persons acting under state law.

Screening standard

Because Singleton was a prisoner permitted to proceed without prepaying filing fees, the court screened the complaint under the Prison Litigation Reform Act. The court was required to dismiss claims that were frivolous, failed to state a legally sufficient claim, or sought monetary relief from an immune defendant. It also had to dismiss claims over which it lacked subject-matter jurisdiction. Although the court was required to read a self-represented litigant’s complaint liberally, the complaint still had to provide enough factual detail to make relief plausible.

Criminal-prosecution request

The court dismissed Singleton’s claims seeking criminal prosecution of the defendants for failure to state a claim. It explained that a private citizen cannot prosecute a criminal action in federal court and has no legally recognized interest in whether another person is prosecuted.

Claims against the State and state court

The court understood the People of the State of New York to mean the State of New York. It held that the State and the New York Supreme Court, Bronx County, were protected by Eleventh Amendment immunity. That doctrine generally prevents suits against a state in federal court unless the state waives its immunity or Congress validly removes it. The court dismissed Singleton’s § 1983 damages claims against those defendants under that doctrine.

Claim against Justice Greenberg

The court dismissed Singleton’s § 1983 damages claims against Justice Ethan Greenberg under judicial immunity. The claims arose from Greenberg’s actions and decisions while presiding over Singleton’s state-court criminal action. The court held that this conduct fell within the scope of Greenberg’s judicial duties and that judicial immunity applied. It dismissed those claims as barred by immunity and as frivolous under the prisoner-screening statute.

Claims against the prosecutors

The court dismissed Singleton’s § 1983 damages claims against Assistant District Attorneys Megan Leo and Allison Kline under prosecutorial immunity. The challenged conduct arose from their prosecution of Singleton. The court held that prosecutors are absolutely immune from damages claims for conduct within their official duties that is closely connected to the judicial phase of a criminal case. It also characterized those claims as frivolous under the prisoner-screening statute.

Claims against Kelly and the New York Defender Service

The court dismissed the remaining § 1983 claims against Jesse Hoberman Kelly and the New York Defender Service for failure to state a claim. Section 1983 generally requires allegations that the defendant acted under color of state law. The court treated Kelly as a private attorney and the New York Defender Service as a private organization, and found that Singleton alleged no facts showing either acted as a state actor.

The court also addressed Singleton’s allegation that defendants conspired to violate his rights by refusing to provide his grand-jury transcripts under a protective order issued by Justice Greenberg. It found those allegations vague and unsupported, and held that they did not state a conspiracy claim under § 1983 or 42 U.S.C. § 1983(5).

Claims involving the Department of Correction and New York City

The court dismissed the claims against the New York City Department of Correction because a New York City agency is not an entity that can be sued. The court understood the claims as also directed against the City of New York. To state a § 1983 claim against the City, Singleton had to allege a city policy, custom, or practice that caused the constitutional violation. The court found that he alleged no such facts and dismissed any § 1983 claims against the City for failure to state a claim.

State-law claims and amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—in accordance with 28 U.S.C. § 1367(c)(3). The court also declined to give Singleton leave to amend because it found that the complaint’s defects could not be cured by amendment.

Disposition

Judge Louis L. Stanton directed the Clerk of Court to mail Singleton a copy of the order and record service on the docket. The court dismissed the action. It dismissed the federal claims as frivolous, for failure to state a claim, or because they sought monetary relief from immune defendants, and declined to consider the state-law claims under supplemental jurisdiction.