Griffith v. AMKC Rikers Island

Background

Brandon Griffith, representing himself, asserted claims under 42 U.S.C. § 1983 and sought damages. His claims concerned two groups of events: his arrest and search by members of the Clarkstown Police Department in West Nyack, Rockland County, New York; and his later confinement at the Anna M. Kross Center (AMKC) on Rikers Island.

The defendants were the Clarkstown Police Department, Police Officer Papenmeyer, an unidentified Clarkstown police sergeant identified as “John Doe,” AMKC Rikers Island, Harts Island, AMKC Deputy Warden Foo, and an unidentified AMKC physician identified as “Dr. Jane Doe.” The court had previously allowed Griffith to proceed without paying filing fees.

Rules the Court Applied

Federal Rule of Civil Procedure 18 allows a plaintiff to join multiple claims against one defendant. Rule 20 allows multiple defendants to be joined only when the claims arise from the same transaction or series of events and involve a common legal or factual question. Rule 21 allows a court to sever, or separate, claims against a party.

In deciding whether to sever claims, the court also considered judicial efficiency, possible prejudice to the parties, and whether the claims would involve different witnesses and evidence.

Ruling

The court concluded that the claims against 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 joining these claims in one action did not comply with Rule 20.

The court therefore severed Griffith’s claims against AMKC Rikers Island, Harts Island, Deputy Warden Foo, and Dr. Jane Doe. It directed the Clerk of Court to open a new, unassigned civil action for those claims and to docket copies of the complaint, Griffith’s amended application to proceed without paying fees, the order granting that application, and this Order in the new action.

The court also certified that any appeal from this Order would not be taken in good faith and denied fee-free status for purposes of an appeal. The Order did not decide the underlying merits of Griffith’s claims.