Singleton v. Office of the Mayor

Background

Aaron Singleton, who was incarcerated at the Anna M. Kross Center on Rikers Island, filed this case without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims against people who violate constitutional rights while acting under state law. The court had already allowed him to proceed without prepaying the filing fee.

Screening standard

Because Singleton was incarcerated and sought relief from government defendants, the court screened his complaint under the Prison Litigation Reform Act. The court had to dismiss claims that were frivolous, malicious, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also said that complaints filed without a lawyer are read liberally, but still must provide a short and plain statement showing entitlement to relief.

Claims against the Department of Correction and Corporation Counsel

The court dismissed the New York City Department of Correction and the Office of Corporation Counsel as defendants. Relying on the New York City Charter and prior decisions, the court held that these City agencies are not entities that can be sued. Under Federal Rule of Civil Procedure 21, the court directed the Clerk of Court to add the City of New York as a defendant because Singleton clearly intended to assert claims against the City. The substitution was without prejudice to defenses the City might later assert.

Claims against the Mayor and Governor

The court explained that a § 1983 claim requires facts showing a defendant’s direct and personal involvement in the alleged constitutional violation. A person cannot be held liable solely because that person supervises someone who allegedly violated the plaintiff’s rights. The court held that Singleton had not alleged personal involvement by Mayor Bill de Blasio or Governor Andrew Cuomo and dismissed the claims against them. The court also noted that Governor Cuomo was immune from damages under the Eleventh Amendment. The order stated that Singleton may file an amended complaint naming individual defendants who were personally involved.

Disposition

The court dismissed the named defendants: the New York City Department of Correction, Mayor Bill de Blasio, Governor Andrew Cuomo, and the City of New York Corporation Counsel. It directed that the City of New York be added as a defendant, requested that the City waive service of summons, and directed notice and mailing of the order to Singleton. The court certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.

Classification

This is a procedural order because the court screened the complaint and dismissed claims for pleading, suability, personal-involvement, and immunity reasons without deciding whether Singleton’s constitutional rights were actually violated.