Monroe v. Rockland County Correctional Facility
- Vincent Briccetti
- 7:20-cv-06807
- U.S. District Court · Southern District of New York
- 6
In Monroe v. Rockland County Correctional Facility, Judge Briccetti dismissed claims against two entities and ordered service on four defendants.
Michael J. Monroe; the Rockland County Correctional Facility and its Medical Department, whose claims were dismissed; and the County of Rockland, Lieutenant John Byron, Captain J.C. Jiska, and HSA Nurse Administrator Jouliana, who were named for service.
What happened
In Monroe v. Rockland County Correctional Facility, Michael J. Monroe, who was representing himself while held at the facility, sought damages and court orders. The court understood his complaint to raise federal civil-rights claims and state-law claims.
The court dismissed Monroe’s claims against the Rockland County Correctional Facility and its Medical Department because those entities were not proper defendants for claims under the federal civil-rights statute. It added the County of Rockland, Lieutenant John Byron, and Captain J.C. Jiska as defendants because the complaint alleged their involvement.
Judge Vincent L. Briccetti ordered the U.S. Marshals Service to serve the County, Byron, Jiska, and HSA Nurse Administrator Jouliana. The court also denied permission to proceed without prepaying fees for any appeal, stating that an appeal would not be taken in good faith.
The detailed version
- Monroe v. Rockland County Correctional Facility · No. 7:20-cv-06807
- Vincent Briccetti
- Aug. 25, 2020
Background
Michael J. Monroe, who was being held at the Rockland County Correctional Facility, filed this action without a lawyer. He sought damages and injunctive relief, meaning court orders requiring or prohibiting conduct. The court construed the complaint as asserting claims under 42 U.S.C. § 1983, the federal civil-rights statute for certain violations by state actors, and under state law. The court had previously allowed Monroe to proceed without prepaying filing fees.
Defendants and Rule 21
The court explained that, under Rule 21 of the Federal Rules of Civil Procedure, it may add or remove parties to promote an efficient and fair case. It concluded that the Rockland County Correctional Facility and the Rockland County Correctional Medical Department were not proper defendants for Monroe’s § 1983 claims because they were administrative arms of the County of Rockland and were not legally separate entities for that purpose.
The court therefore dismissed Monroe’s claims against the Rockland County Correctional Facility and the Rockland County Correctional Medical Department. It added the County of Rockland, Lieutenant John Byron, and Captain J.C. Jiska as defendants because Monroe’s complaint alleged that Byron and Jiska were involved in the events at issue. The court stated that this change to the case caption was without prejudice to defenses that the County, Byron, or Jiska might assert.
Service of process
Because Monroe was allowed to proceed without prepaying fees, the court directed the Clerk of Court and the U.S. Marshals Service to handle service. The court ordered the Clerk to issue summonses and prepare service forms for the County of Rockland, Byron, Jiska, and HSA Nurse Administrator Jouliana, and to provide the necessary documents to the Marshals Service.
The court extended the time for service until 90 days after summonses were issued for those defendants. It also instructed Monroe to notify the court in writing if his address changed and stated that the action could be dismissed if he failed to do so.
Disposition
The court dismissed the claims against the Rockland County Correctional Facility and the Rockland County Correctional Medical Department, added the County of Rockland, Byron, and Jiska as defendants, and directed service on those three defendants and Jouliana. The order did not decide whether Monroe’s underlying claims were legally valid. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. Judge Vincent L. Briccetti signed the order on August 25, 2020.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.