Jackson v. Cuomo

Background

Eric Jackson brought this action under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by government officials acting under state authority. He was detained at Fishkill Correctional Facility and represented himself. Jackson alleged that he had been held there for months beyond the maximum release date for his conviction because the defendants failed to help him locate housing that complied with the Sexual Assault Reform Act, a New York law identified in the opinion. He sought damages and injunctive relief, meaning a court order requiring or prohibiting conduct.

The court had previously allowed Jackson to proceed without paying the filing fee in advance. Because he was a prisoner seeking relief from government defendants, the Prison Litigation Reform Act required the court to screen his complaint. 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 explained that it must read filings by people without lawyers generously, while still requiring a short and plain statement showing entitlement to relief.

Claims Against New York State Agencies

The court held that the Eleventh Amendment generally bars lawsuits in federal court against states and state entities unless the state has waived its immunity or Congress has removed it. The court stated that New York had not waived this immunity and that Congress had not removed it when it enacted Section 1983. It therefore dismissed Jackson’s Section 1983 claims against the New York State Division of Parole and the New York State Board of Parole. The opinion states this disposition as a dismissal under 28 U.S.C. § 1915(e)(2)(B)(iii).

Service on Individual Defendants

The court did not dismiss the claims against Fishkill Superintendent Leroy Fields, Fishkill Offender Rehabilitation Coordinator Beverly Lockwood, Governor Andrew Cuomo, or Anthony J. Annucci, identified as Commissioner of the New York State Department of Correction and Community Supervision. Because Jackson was allowed to proceed without prepaying the filing fee, the court directed the U.S. Marshals Service to serve those defendants.

The court extended the service period to 90 days after the summons is issued. It instructed the Clerk of Court to prepare a service form for each individual defendant, issue the summonses, and provide the Marshals Service with the necessary documents. The court also stated that Jackson must notify the court in writing if his address changes and that the action could be dismissed if he failed to do so.

Disposition

Judge Kenneth M. Karas dismissed Jackson’s claims against the New York State Division of Parole and the New York State Board of Parole. The Clerk of Court was directed to prepare and send the documents needed for service on Fields, Lockwood, Cuomo, and Annucci. The order did not decide the underlying allegations against those individual defendants.