Griffith v. Clarkstown Police Dept.
- Philip Halpern
- 7:20-cv-06505
- U.S. District Court · Southern District of New York
- 4
In Griffith v. Clarkstown Police Dept., Judge Halpern severed unrelated Rikers Island claims into a new case under federal joinder rules.
Brandon Griffith’s claims against AMKC Rikers Island, Harts Island, Deputy Warden Foo, and Dr. Jane Doe were separated from this action and directed into a new civil case. The order also affected Griffith’s ability to appeal this order without prepaying fees.
What happened
Griffith v. Clarkstown Police Dept. involves Brandon Griffith’s claims about his arrest and search by Clarkstown police and his later confinement at the Anna M. Kross Center on Rikers Island. He sued under a federal civil-rights law and requested money damages.
The court found that the claims about the Rikers Island confinement involved different events, defendants, witnesses, and evidence from the claims about the arrest and search in Rockland County. The court therefore determined that the claims could not be pursued together in this lawsuit.
Judge Philip M. Halpern severed the claims against the Rikers Island facility, Harts Island, Deputy Warden Foo, and Dr. Jane Doe, and directed the clerk to open a new civil case for them. The court also denied fee-free status for any appeal from this order.
The detailed version
- Griffith v. Clarkstown Police Dept. · No. 7:20-cv-06505
- Philip Halpern
- Jan. 14, 2021
Background
Brandon Griffith appeared without a lawyer and asserted claims under 42 U.S.C. § 1983, a federal law allowing claims for violations of constitutional rights by state actors. He sought damages based on two groups of events: (1) his arrest and search by members of the Clarkstown Police Department in West Nyack, Rockland County, New York; and (2) his later confinement at the Anna M. Kross Center on Rikers Island.
Griffith named the Clarkstown Police Department, Police Officer Papenmeyer, an unidentified Clarkstown police sergeant, AMKC Rikers Island, Harts Island, Deputy Warden Foo, and an unidentified AMKC physician, Dr. Jane Doe. The court had previously allowed him to proceed without prepaying filing fees.
Reason for Severance
Federal Rule of Civil Procedure 18 allows a plaintiff to bring multiple claims against one defendant. Rule 20, however, limits when multiple defendants may be joined in one lawsuit. The claims must arise from the same transaction or series of transactions, and the lawsuit must involve a common legal or factual question. Rule 21 allows a court to sever a claim against a party when appropriate.
The court concluded that the claims involving the AMKC defendants and Harts Island arose from events at AMKC on Rikers Island, while the claims against the Clarkstown defendants arose from events in Rockland County. The court determined that these events did not satisfy the requirements for joining the defendants in one action. It also considered the logical relationship between the claims, judicial efficiency, possible prejudice, and whether the claims would involve different witnesses and evidence.
Ruling
Judge Philip M. Halpern severed from this action Griffith’s claims against AMKC Rikers Island, Harts Island, Deputy Warden Foo, and Dr. Jane Doe. The court directed the clerk to open a new unassigned civil action for those claims and to docket copies of the complaint, Griffith’s amended application to proceed without prepaying fees, the earlier order granting that request, and this order in the new case.
The court also certified that any appeal from the order would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not decide the merits of Griffith’s underlying arrest, search, or confinement claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.