Jones v. Westchester County

Background

Daniel T. Jones, who was incarcerated at Attica Correctional Facility when he filed the complaint, alleged that in January 2018 he fell down stairs at Westchester County Jail after slipping on a wet mop. He alleged that Dr. Raul Ulloa did not send him to an outside hospital that day, that jail medical personnel did not obtain an MRI or CAT scan after an outside doctor diagnosed a sprained ankle, and that his request for stronger pain medication was denied. He sued under 42 U.S.C. § 1983, a federal civil-rights statute, and also asserted state-law claims for medical malpractice, negligence, and intentional infliction of emotional distress.

The court had previously allowed Jones to proceed without paying filing fees. Because Jones was a prisoner proceeding without a lawyer, the court screened the complaint under federal prisoner-screening statutes. The court explained that it had to dismiss claims that were frivolous, malicious, failed to state a legally sufficient claim, sought relief from an immune defendant, or fell outside the court’s jurisdiction. It also explained that although complaints filed without a lawyer are read liberally, they still must provide enough facts to make a claim plausible.

Rulings on the Defendants

The court dismissed the claims against the Westchester County Department of Corrections because, under New York law, a municipal department lacks a separate legal identity and cannot be sued in its own name. The court directed that any such claims instead be asserted against Westchester County, which Jones had already named.

The court found that Jones failed to state a § 1983 claim against Westchester County. A municipality is not liable merely because one of its employees allegedly acted improperly; the complaint must allege a municipal policy, custom, or practice that caused the constitutional violation. Jones alleged inadequate medical care but did not allege facts showing that a Westchester County policy or custom caused the alleged violation. The court stated that any amended complaint must provide those facts if Jones continues to pursue the claim.

The court also found that Jones’s allegations did not state a deliberate-indifference claim against Dr. Ulloa. The alleged failure to send Jones immediately to an outside hospital, followed by evaluation at the jail clinic and an outside hospital the next day, did not sufficiently show a serious risk of harm caused by the delay or that Dr. Ulloa knew or should have known of such a risk. The allegations that jail medical personnel should have challenged the outside doctor’s sprained-ankle diagnosis and ordered additional testing amounted, at most, to a disagreement over treatment. The court likewise held that the choice to provide one pain medication rather than stronger medication did not state deliberate indifference. The opinion did not identify the Doe defendants or resolve the state-law claims on their merits.

Leave to Amend and Disposition

The court granted Jones 60 days to file an amended complaint that would completely replace, rather than supplement, the original complaint. The amended complaint must identify the relevant defendants and facts, including what each defendant did, when and where the events occurred, how Jones was injured, and what relief he seeks. Jones could use John Doe or Jane Doe designations for unidentified defendants, but the court stated that doing so would not pause the three-year limitations period and that he remained responsible for identifying those defendants and amending the pleading.

The court directed the Clerk to mail the order to Jones and stated that no summons would issue at that time. The court dismissed Jones’s claims against the Westchester County Department of Corrections. It did not dismiss the remaining federal claims in the present order; instead, it warned that if Jones failed to amend within the allowed period without showing good cause, the § 1983 claims would be dismissed for failure to state a claim and the court would decline to exercise supplemental jurisdiction over the state-law claims. The order was signed by United States District Judge Louis L. Stanton.