Walden v. The City of New York and Municipality of New York County

Background

John Walden filed a civil-rights complaint under 42 U.S.C. § 1983 while incarcerated at Orleans Correctional Facility and proceeding without a lawyer. The court had dismissed his original complaint on December 18, 2020. The court later received an amended complaint dated December 14, 2020. Applying the prison-mailbox rule, which treats a prisoner’s filing as submitted when given to prison officials for mailing, the court treated the amended complaint as filed before the December 18 dismissal.

The amended complaint named the same defendants: the City of New York and Municipality of New York County; Cyrus Vance Jr.; Shilpa Kalra; James Meehan; Steve Stanley; and the City of New York Department of Law. It repeated allegations that the defendants arrested, detained, and prosecuted Walden using fabricated or manufactured documents, including a warrant, grand-jury minutes, and an arraignment sheet. The amended complaint did not include his claims arising from an incident at Orleans Correctional Facility.

Reasons for the Earlier Dismissal

The court’s December 18 order dismissed the claims against Vance and Kalra based on prosecutorial immunity. It dismissed the claims against the New York City Law Department because a city agency is not an entity that can be sued. It dismissed the claims against the City of New York for failure to state a claim because Walden had not alleged facts suggesting that a city policy, custom, or practice caused a constitutional violation.

The court dismissed the claims against detectives Meehan and Stanley under the favorable-termination rule from Heck v. Humphrey because Walden’s conviction had not been overturned or vacated. It also dismissed claims arising from the Orleans Correctional Facility incident because Walden had not alleged that any named defendant was personally involved in violating his rights. The court noted that venue for those claims was not proper in the Southern District of New York, but declined to sever and transfer them because they failed to state a claim.

Ruling

The court concluded that the amended complaint had the same defects as the original complaint and dismissed it for the same reasons stated in the December 18 order. The court declined to give Walden another opportunity to amend because it determined that the defects could not be cured through further amendment. The court directed the clerk to mail Walden a copy of the order and stated that the action remains closed.

Disposition

The amended complaint was dismissed. The court also declined to grant leave to file another amended complaint.