Singleton v. New York City Police Department

Background

Aaron Singleton filed an amended complaint without a lawyer while being held at Rikers Island and proceeding without paying the filing fee. He sued the New York City Police Department, the New York City Corporation Counsel, Police Officer Dino Davila, the police officers from the 46th Precinct involved in arrest #B18645572, Police Sergeant Chikel Ian, Bronx County Assistant District Attorney Yuri Chornobil, and Bronx County Assistant District Attorney Allison Kline.

Singleton’s claims arose from his October 7, 2018 arrest and later detention. He alleged that officers arrested him without probable cause or a warrant and used excessive force. He also alleged that Chornobil interrogated him after his arrest and that Kline was prosecuting the related state criminal case while withholding exculpatory evidence. In addition to damages, he sought relief challenging the constitutionality of his pretrial custody under 28 U.S.C. § 2241.

Court’s analysis

The court screened the amended complaint under the Prison Litigation Reform Act, which requires courts to dismiss certain prisoner complaints that are frivolous, fail to state a legally sufficient claim, seek money from an immune defendant, or otherwise fall outside the court’s jurisdiction.

The court dismissed the damages claims against Kline because prosecutors have immunity from damages suits for conduct closely connected to prosecuting a criminal case. It also applied that immunity to Singleton’s claims against Chornobil to the extent they concerned evaluating evidence and interviewing him to determine whether to prosecute.

The court dismissed the claims against the Corporation Counsel and Sergeant Ian because Singleton alleged no facts showing either defendant’s personal involvement in a constitutional violation. It again dismissed the claims against the NYPD because the agency is not a suable entity and dismissed the claims construed as being against the City of New York for failure to state a claim.

The court dismissed claims seeking an order that would interfere with Singleton’s ongoing state criminal proceedings under the Younger abstention doctrine. The court also dismissed the § 2241 custody claims without prejudice because Singleton merely asserted that he had exhausted available state remedies and alleged no facts showing that he had done so.

The court had previously allowed Singleton to amend his claims for false arrest, false imprisonment, and excessive force. The court held that his amended allegations—that officers lacked probable cause and used excessive force—were only conclusions and did not provide supporting facts. It therefore dismissed those claims for failure to state a claim.

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning its additional authority over related state-law claims, and therefore declined to consider any state-law claims Singleton may have asserted.

Disposition

The court dismissed the action. It dismissed Singleton’s federal claims as frivolous, for failure to state a claim, because some defendants were immune from monetary relief, and under the Younger abstention doctrine. To the extent Singleton asserted claims challenging his pretrial custody under 28 U.S.C. § 2241, the court dismissed those claims without prejudice. The court declined to consider the state-law claims under its supplemental jurisdiction.