Graham v. Moran

Background

Roland Graham, who was incarcerated at the Philadelphia Industrial Correctional Center, filed this case without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain claims for violations of constitutional or federal rights. He sued Alina Moran, identified as the chief executive officer of Metropolitan Hospital; Ms. J. Chavez, identified as director of mental health records; and Oquendo, identified as a director. The opinion states that the defendants were associated with Metropolitan Community Hospital in Manhattan.

Graham alleged that the defendants failed to release his medical records for his trial, even though he had signed a form provided by Chavez. He said the defendants disregarded his right to obtain the records, which deprived him of the opportunity to present a major expert witness who had treated his mental illness. He characterized the defendants’ conduct as deliberate indifference and discrimination and sought millions of dollars in damages. He also asked the court to request a pro bono lawyer.

Court’s analysis

The court screened Graham’s complaint under the federal statutes requiring dismissal of an incarcerated person’s complaint filed without prepaying fees if it is frivolous, malicious, fails to state a claim, or seeks relief from an immune defendant. The court dismissed the action for failure to state a claim.

First, the court held that Graham could not seek damages under § 1983 based on conduct that, if unlawful, would necessarily show that his criminal conviction was invalid. Such a claim is barred unless the conviction has already been reversed, expunged, declared invalid by an authorized state tribunal, or called into question by a federal court. The court found no indication that Graham’s conviction had been invalidated in any of those ways.

The court also explained that § 1983 does not provide a claim based solely on violations of state law. Even if Graham’s allegations were understood as invoking New York’s Freedom of Information Law or New York Mental Hygiene Law § 33.16, those state-law provisions did not create a viable § 1983 claim. The court further stated that the Health Insurance Portability and Accountability Act, a federal law concerning health-information privacy and accuracy, does not provide individuals with a private right to sue.

Other motion and disposition

Because it was not clear that Graham could state a viable claim, the court denied his application for pro bono counsel without prejudice to renewal at a later stage. The court granted Graham 30 days to file an amended complaint alleging facts showing that he could state a viable claim. It also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.