Murphy v. Spaulding

Background

Mark P. Murphy, a pretrial detainee held at the Westchester County Jail, filed this action without a lawyer and sought damages. The court construed his allegations as claims under 42 U.S.C. § 1983, a federal law allowing claims against state or local officials for violating federal rights. Murphy sued Assistant Warden La. Spaulding, Sergeant Carrozza, and Correctional Officers Iaboni and Schmitt.

Murphy alleged that on September 23, 2020, Carrozza, Iaboni, and Schmitt escorted another prisoner toward suicide watch. The prisoner was handcuffed in front, was not pat-frisked, and then threw a shampoo bottle containing an unknown substance at Murphy as the prisoner passed Murphy’s cell. Murphy later received Benadryl and cortisone cream for a rash. Murphy filed a grievance, and Spaulding partially reversed the grievance’s denial, agreeing that the other prisoner should have been searched for weapons or contraband before the escort.

Screening standard

The court reviewed the complaint under the Prison Litigation Reform Act, which requires courts to screen certain prisoner complaints. The court must dismiss claims that are frivolous, malicious, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. Although courts read complaints filed without lawyers liberally, the complaint still must provide enough factual detail to make a claim plausible rather than merely possible.

Failure-to-protect claim

The court treated Murphy’s allegations as a claim that the defendants violated his rights under the Due Process Clause of the Fourteenth Amendment by failing to protect him from another prisoner’s attack. Such a claim requires allegations showing both an objectively serious risk to health or safety and that a jail official intentionally imposed the condition or recklessly failed to take reasonable steps to reduce a known or knowable excessive risk. Mere negligence is not enough.

The court stated that, even assuming Murphy satisfied the objective-risk requirement, he had not alleged facts showing that any defendant acted intentionally or recklessly while knowing, or having reason to know, that the other prisoner posed an excessive risk to Murphy’s health or safety. The court therefore found that Murphy had not alleged enough facts to state a claim, but granted him leave to amend because he was proceeding without a lawyer.

Spaulding’s personal involvement

The court also explained that a § 1983 plaintiff must allege each defendant’s direct and personal involvement in the alleged constitutional violation. A supervisor cannot be held liable merely because the supervisor employs or oversees someone who allegedly violated the plaintiff’s rights.

The court found that Murphy’s allegations about Spaulding—that Spaulding fostered an atmosphere allowing such incidents and partially reversed the grievance decision—did not show personal involvement in a constitutional violation. The court granted Murphy leave to allege facts showing how each defendant named in the amended complaint was personally involved.

Order

The court granted Murphy leave to file an amended complaint within 60 days. The amended complaint had to include a short and plain statement of the facts, identify each defendant’s acts or omissions, provide relevant dates and locations, describe the injuries and rights allegedly violated, and state the requested relief. It would replace the original complaint rather than supplement it. The court directed that no summons issue at that time and warned that failure to amend without good cause would result in dismissal for failure to state a claim.