Griffith v. AMKC Rikers Island

Background

Brandon Griffith filed this civil-rights action without a lawyer. The court treated his allegations as claims under 42 U.S.C. § 1983, the federal law that allows a person to sue a state or local government actor for violating federal rights, and under state law. Griffith alleged that Clarkstown Police Department members arrested him on May 9, 2018, and later transferred him to the custody of the New York City Department of Correction. While held at the Anna M. Kross Center, he suffered a mental breakdown, attempted suicide twice, and was hospitalized.

Griffith alleged that AMKC Deputy Warden Foo and Dr. Jane Doe, whom the opinion describes as an unidentified physician employed at AMKC, were responsible for failing to provide adequate medical attention. The case had originally been part of another action and was later severed into this separate case.

Screening standard

Because Griffith filed the complaint while incarcerated and had permission to proceed without paying the filing fee in advance, the Prison Litigation Reform Act required the court to screen the complaint. The court had to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought relief from an immune defendant, or fell outside the court’s jurisdiction. The court also explained that complaints filed without a lawyer are read liberally, but still must provide enough factual detail to make a claim plausible.

Claims against AMKC Rikers Island and Harts Island

The court dismissed Griffith’s § 1983 claims against AMKC Rikers Island and Harts Island for failure to state a claim. It held that AMKC, a New York City jail, and Hart Island, which the complaint called Harts Island, are locations rather than legal persons subject to suit under § 1983.

Because the locations are managed by the New York City Department of Correction, the court interpreted the complaint as potentially asserting claims against the City of New York. To state a § 1983 claim against the City, Griffith needed to allege facts showing that a City policy, custom, or practice caused the alleged constitutional violation. The court found that he had not alleged those facts. It granted him leave to amend by naming the City and providing facts sufficient to state such a claim.

Medical- and mental-health-care allegations

The court explained that claims about inadequate medical care by a parolee are analyzed under the Fourteenth Amendment standard applied to pretrial detainees. Griffith needed to allege both a sufficiently serious medical or mental-health need and facts showing that officials acted with the required level of deliberate indifference. For a parolee, this could include allegations that officials knew, or should have known, that failing to provide treatment created a substantial risk to his health. Mere negligence would not be enough.

The court found that Griffith had not alleged facts showing how any official was deliberately indifferent to his serious medical or mental-health needs in May 2018. It granted him leave to amend and provide those facts.

Personal involvement of the individual defendants

A § 1983 claim against an individual defendant requires facts showing that the defendant was personally and directly involved in the alleged constitutional violation. A supervisor cannot be held liable merely because someone the supervisor oversees allegedly violated the plaintiff’s rights.

The court found that Griffith’s statements that Foo and Dr. Jane Doe were responsible for failing to provide adequate medical attention, and acted with malice and deliberate indifference, did not explain how either person was directly involved. The court granted him leave to identify the people personally involved and describe what each person did or failed to do.

Leave to amend and disposition

The court granted Griffith leave to file an amended complaint. It directed him to identify defendants in both the caption and the factual section, provide relevant dates, places, actions, injuries, and requested relief, and repeat any facts or claims from the original complaint that he wanted the court to consider. He could use “John Doe” or “Jane Doe” for an unidentified defendant, but the court warned that doing so would not pause the three-year limitations period.

The court dismissed Griffith’s claims against AMKC Rikers Island and Harts Island. It granted him 60 days from the date of the order to submit an amended complaint. The order warned that, if he failed to comply without showing good cause, the court would dismiss his remaining federal claims for failure to state a claim and would decline to consider his state-law claims under supplemental jurisdiction. Judge Louis L. Stanton signed the order.