Madison v. Lincoln Hospital Emergency Unit

Background

Malcolm Madison, proceeding without a lawyer, sued “Lincoln Hospital Emergency Unit on 149 St in the Bronx New York” for damages. The court understood his complaint to assert claims under 42 U.S.C. § 1983, the federal civil-rights statute, and under state law. The court had previously allowed him to proceed without paying filing fees.

Madison alleged that he went to Lincoln Hospital’s emergency room on January 18, 2021, because his legs and feet were swollen and he had lower-back pain. Hospital officials registered him, took his vital signs, and told him to wait for a physician, but he alleged that no physician examined him. At about 2:00 a.m., security guards asked him to put on his shoes. He said his feet were swollen and that he was waiting for a physician. He also alleged that guards refused his request to use a restroom, after which he urinated into a sink. The guards then asked him to leave. When Madison said he still had not seen a physician, a guard allegedly told him that he was not going to see one. Madison asked the guards to call the police, and he alleged that one guard grabbed him, threatened to “bust [his] head open,” and responded with profanity after Madison said “Black Lives Matter.” Madison alleged that he received no medical treatment and felt traumatized and abused.

Federal claims

The court applied the screening standard for complaints filed without prepayment of fees. Under that standard, the court must dismiss a complaint that is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. Although courts interpret complaints filed by people without lawyers liberally, those complaints still must provide enough factual detail to make the requested relief plausible.

To state a claim under § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and action by a person acting under state law. The court dismissed Madison’s § 1983 claim against Lincoln Hospital because a hospital is not a “person” that can be held liable under § 1983.

The court then treated Madison’s claims against the hospital as claims against New York City Health + Hospitals, the public benefit corporation that operates Lincoln Hospital. To hold that entity liable under § 1983, Madison had to allege that an organizational policy, custom, or practice caused the violation of his rights. The court found that he alleged no such policy, custom, or practice and dismissed the § 1983 claims against Health + Hospitals for failure to state a claim.

The court also stated that Madison had not alleged facts showing that Health + Hospitals had an affirmative constitutional duty to provide him with medical treatment. It further stated that threats, verbal harassment, and profanity, without injury or damage, generally do not create a § 1983 claim.

State-law claims

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—over any state-law claims Madison might have asserted. The court relied on the general principle that a federal court may decline state-law jurisdiction when the federal claims have been dismissed at an early stage.

Leave to amend and disposition

The court denied Madison leave to amend because it found that the defects in his complaint could not be cured by amendment. Judge Louis L. Stanton directed the Clerk of Court to mail Madison a copy of the order and note service on the docket. The court dismissed the action, dismissed the federal claims for failure to state a claim, and declined to consider the state-law claims under supplemental jurisdiction.