Taylor v. The State of New York

Background

Chester Taylor, who was detained at the Vernon C. Bain Center, filed this lawsuit without a lawyer under 42 U.S.C. § 1983. He alleged that the State of New York and the “Department of Correction”—which the court understood to mean the New York City Department of Correction—violated his constitutional rights by failing to protect him from contracting COVID-19. Taylor originally filed the complaint with 41 other detainees, but the court had previously separated their claims, leaving Taylor as the sole plaintiff.

Taylor alleged that he was housed in Dorm 1BB, which had a maximum capacity of 50 beds and housed 44 detainees. He said social distancing was not followed, the sleeping and day-room areas had no windows, air circulation came from one fan that blew dust around the dorm, and the Department of Correction took no specific measures to protect detainees’ health. He also alleged that detainees experienced coughing, sore throats, headaches, dizziness, and COVID symptoms. He sought money damages.

Court’s analysis

The court applied the required screening rules for prisoner complaints seeking relief from governmental entities. Those rules require dismissal of claims that are frivolous, malicious, fail to state a claim, seek money from an immune defendant, or fall outside the court’s jurisdiction. The court also explained that complaints filed by people without lawyers are read generously but still must provide enough facts to make a legal claim plausible.

The court held that Taylor’s claims against the State of New York were barred by the Eleventh Amendment, which generally protects states from being sued in federal court unless an exception applies. The court stated that New York had not waived that protection and that Congress had not removed it when it enacted Section 1983. The court also stated that the claims would fail for another reason because the Vernon C. Bain Center was operated by the New York City Department of Correction, not a state facility.

The court held that the Department of Correction, as a New York City agency, could not be sued as a separate entity. Because the complaint showed that Taylor intended to assert claims against New York City, the court directed the clerk to replace the Department of Correction with the City of New York in the case caption. This change was without prejudice to any defenses the City might later raise.

The court explained that a Section 1983 claim against a city requires facts showing that a city policy, custom, or practice caused the alleged constitutional violation. The court also explained that claims against individual correction officials would require facts showing both that the conditions posed an unreasonable risk of serious harm and that each official acted with the required level of deliberate indifference. The complaint did not name individual defendants or provide enough facts to state such a claim.

Disposition

The court dismissed Taylor’s claims against the State of New York and the Department of Correction. It directed the clerk to add the City of New York as a defendant and granted Taylor leave to file an amended complaint within 60 days. The amended complaint must identify the relevant conditions, explain whether Taylor was a pretrial detainee, identify any involved individuals and their personal involvement, describe his injuries and the requested relief, and include all facts and claims he wanted the court to consider. The court stated that the amended complaint would replace, rather than supplement, the original complaint.

No summons would issue at that time. The court warned that failure to file a compliant amended complaint within the deadline, without good cause, would result in dismissal for failure to state a claim. It also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The order did not decide whether the alleged COVID-related conditions violated Taylor’s constitutional rights.