Young v. The State of New York

Background

Daniel Young, who was detained at the Vernon C. Bain Center, brought this action without a lawyer under 42 U.S.C. § 1983. He alleged that the State of New York and the New York City Department of Correction were violating his federal constitutional rights by failing to protect him from contracting COVID-19. Young originally filed the complaint with 41 other detainees, but the court had already separated their claims, leaving Young as the sole plaintiff.

Young alleged that the housing unit held 44 detainees despite having a maximum capacity of 50 beds, making social distancing impossible. He also alleged that staff did not follow proper social-distancing procedures, the day room and sleeping area had no windows, one fan circulated dust, and the Department of Correction had taken no specific measures to protect detainees. He reported coughing, sore throat, headaches, dizziness, and COVID-19 symptoms. He sought money damages.

Court’s analysis

The court screened the complaint under laws requiring review of prisoner complaints against governmental entities. It explained that a complaint must contain enough factual detail to make a claim plausible, even when filed by someone without a lawyer.

Claims against the State of New York

The court dismissed Young’s section 1983 claims against the State of New York. It ruled that New York had not given up its protection under the Eleventh Amendment from being sued in federal court, and Congress had not removed that protection through section 1983. The court also noted that, even without that protection, the complaint would not state a claim against the State because the Vernon C. Bain Center is operated by the New York City Department of Correction rather than a state facility.

Claims involving the Department of Correction and the City

The court dismissed the claims against the Department of Correction because a New York City agency is not an entity that can be sued separately. Because the court understood Young to intend to sue the City of New York, it directed the Clerk to replace the Department of Correction with the City as a defendant. The court stated that this change was without prejudice to defenses the City might assert.

To state a section 1983 claim against the City, Young’s amended complaint would need to allege that a City policy, custom, or practice caused the alleged constitutional violation. The court explained that allegations of wrongdoing by an employee alone would not be enough.

Individual defendants and conditions of confinement

The complaint did not name individual defendants and did not contain enough facts to state a claim based on the conditions at the detention center. The court explained that the legal standard would depend partly on whether Young was a pretrial detainee or a convicted prisoner. In either event, he would need to allege that the conditions created an unreasonable risk of serious harm and that the responsible officials acted with the required level of disregard for that risk. For a pretrial detainee, the relevant inquiry would include whether an official intentionally imposed the condition or recklessly failed to act with reasonable care despite knowing, or having reason to know, of an excessive risk. For a convicted prisoner, he would need to allege that an official knew of and disregarded the excessive risk.

The court directed Young to state whether he was a pretrial detainee, identify the housing units involved, describe the specific conditions, explain how those conditions created a substantial risk of serious harm, and provide facts showing the defendants’ involvement. If he named individual defendants, he would need to describe each person’s personal involvement.

Leave to amend and disposition

The court granted Young leave to file an amended complaint within 60 days. The amended complaint had to completely replace the original complaint and include all facts and claims Young wanted the court to consider. It had to identify the defendants, describe what each defendant did or failed to do, provide approximate dates and locations, describe injuries, and state the requested relief. The court allowed use of “John Doe” or “Jane Doe” if Young did not know an individual’s name, but warned that doing so would not stop the three-year limitations period from running.

The court dismissed Young’s claims against the State of New York and the Department of Correction, directed the Clerk to add the City of New York as a defendant, and granted leave to amend. No summons would issue at that time. 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.