Jones v. New York City Department Of Corrections

Background

Michael Jones brought a self-represented action under 42 U.S.C. § 1983, which allows claims for violations of federal rights by state actors. He alleged that, while in the custody of the New York City Department of Correction at West Facility on Rikers Island, he was placed in administrative segregation without notice, a stated reason, a chance to challenge the placement, or periodic review. He alleged that the placement was based on his being gay and on his unspecified religion.

Jones further alleged that he was confined to his cell for 24 hours a day and denied recreation and access to the law library. He asserted that the lack of law-library access resulted in his conviction. He also alleged that officials denied him mental-health counseling and batteries for his hearing aid. He sought money damages and closure of the West Facility compound. The court had previously granted him permission to proceed without prepaying filing fees.

Screening of the Complaint

Because Jones was proceeding without a lawyer and sought relief against governmental entities, the court screened his complaint under the Prison Litigation Reform Act. The court explained that it had to dismiss claims that were frivolous, malicious, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s jurisdiction. It also explained that self-represented complaints are read generously but still must provide enough facts to make a claim plausible.

Claims Against the Department of Correction and Facilities

The court dismissed claims against the New York City Department of Correction because a New York City agency generally is not a suable entity. It also dismissed claims against West Facility and Rikers Island because a jail or correctional facility is not a “person” that can be sued under § 1983.

Claims Against New York City

The court dismissed any claims against New York City. A municipality is not liable under § 1983 merely because one of its employees allegedly committed misconduct. Jones needed to allege facts showing both a city policy, custom, or practice and a connection between that policy, custom, or practice and the alleged constitutional violation. The court found that he had not done so. The court noted that his allegations instead suggested that the New York City Board of Correction had informed the Department of Correction that the City did not have a policy authorizing the alleged violations.

Due Process Claims

The court interpreted Jones’s allegations as raising Fourteenth Amendment substantive- and procedural-due-process claims concerning his placement in administrative segregation. For substantive due process, the relevant question was whether the restrictions were imposed as punishment or were reasonably related to another legitimate government purpose and not excessive in relation to that purpose.

For procedural due process, the court explained that a pretrial detainee generally has a liberty interest in avoiding administrative segregation. Depending on whether the placement was punitive or administrative, the detainee must receive notice of the reason for placement, an opportunity to respond, and periodic review of whether continued segregation is justified. If the placement was punitive, additional disciplinary procedures may be required.

The court did not finally resolve the adequacy of Jones’s due-process allegations. It directed him to name the individuals personally and directly involved, repeat the facts from his original complaint, and add facts supporting his claim that those individuals placed him in segregation without required procedures.

Medical-Care Claims

The court treated Jones’s allegations about mental-health treatment and hearing-aid batteries as Fourteenth Amendment medical-care claims because the court assumed he was a pretrial detainee. Such a claim requires facts showing an objectively serious risk to health or safety and that the official intentionally imposed the condition or recklessly failed to take reasonable care despite knowing, or having reason to know, of an excessive risk.

The court found that Jones had not described his mental illness or alleged facts showing that the lack of mental-health treatment or hearing-aid batteries created an unreasonable risk of serious harm. He also had not alleged facts showing that a particular defendant knew or should have known about the risk and failed to respond reasonably. The court granted leave to amend these claims by identifying the individuals who denied care and adding supporting facts.

Leave to Amend and Disposition

The court granted Jones 60 days to file an amended complaint. The amended complaint had to name the defendants in both the caption and the factual allegations, describe what each defendant did, state when and where the events occurred, describe his injuries, and identify the relief sought. If he did not know a defendant’s name, he could use “John Doe” or “Jane Doe,” but the order explained that doing so would not pause the applicable three-year limitations period.

The amended complaint would replace the original complaint rather than supplement it, so Jones had to repeat any facts or claims he wanted the court to consider. The court directed the Clerk to mail the order and stated that no summons would issue at that time. If Jones failed to comply within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.