McDaniel v. The City of New York
- Louis Stanton
- 1:20-cv-02832
- U.S. District Court · Southern District of New York
- 8
In McDaniel v. The City of New York, Judge Stanton dismissed the action after finding the amended complaint did not state a federal claim.
Curtis McDaniel’s claims against the City of New York and related state-law claims were affected; the court dismissed the federal claims and declined to consider the state-law claims.
What happened
McDaniel v. The City of New York concerned Curtis McDaniel’s amended complaint about his treatment in jail and issues connected to his criminal case. He sued only the City of New York and requested money damages. The court treated his claims as federal civil-rights claims and state-law claims.
The court dismissed the federal claims because McDaniel did not allege that a City policy, custom, or practice caused a violation of his constitutional rights. His amended complaint replaced the earlier complaint, so the court treated his claims against individual defendants and his request to challenge his custody as abandoned. The court also declined to consider the state-law claims after dismissing the federal claims.
Judge Louis L. Stanton ordered that the action be dismissed. The order dismissed the claims under 42 U.S.C. § 1983 for failure to state a claim and declined supplemental jurisdiction over the state-law claims.
The detailed version
- McDaniel v. The City of New York · No. 1:20-cv-02832
- Louis Stanton
- Sept. 22, 2020
Background
Curtis McDaniel was incarcerated at Bare Hill Correctional Facility and represented himself without a lawyer. He initially asserted claims that the court construed as requests to challenge his custody under 28 U.S.C. § 2254, claims for damages under 42 U.S.C. § 1983, and state-law claims. The court gave him permission to file an amended complaint.
McDaniel’s amended complaint named only the City of New York and sought only damages. He described alleged failures to provide medication and medical care while he was held on Rikers Island. He also asserted claims involving his arrest, imprisonment, prosecution, bail, speedy-trial issues, and the actions of several state-court judges. He alleged violations of constitutional rights and asserted state-law claims.
Court’s analysis
Because the amended complaint named only the City and sought damages, the court treated McDaniel’s claims against individual defendants and his claims seeking custody-related relief as abandoned. The court construed the remaining allegations as claims under § 1983 and state-law claims against the City.
The court screened the complaint under the Prison Litigation Reform Act. It had previously told McDaniel that, to state a § 1983 claim against the City, he had to allege facts showing that a City policy, custom, or practice caused a violation of his federal constitutional rights. The court found that the amended complaint alleged no such facts. It therefore dismissed the § 1983 claims against the City for failure to state a claim on which relief may be granted.
The court also stated that, even if it treated the amended complaint as asserting § 1983 claims against the individual judges, those claims would be dismissed under judicial immunity and as legally frivolous. The court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—after dismissing all claims over which it had original federal jurisdiction.
Disposition
Judge Louis L. Stanton ordered the Clerk of Court to mail the order to McDaniel and record service on the docket. The court dismissed the action, dismissed McDaniel’s § 1983 claims for failure to state a claim, and declined to consider his state-law claims under supplemental jurisdiction. The opinion does not specify whether the dismissal was with or without prejudice.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.