Roundtree v. NYC

Background

Juel Roundtree was held in New York City Department of Corrections custody from May 26, 2015, through December 7, 2017. He had several documented medical conditions, including chronic pain, a torn meniscus, rotator cuff syndrome, osteoarthritis, and obesity. He claimed that the jail’s mattress and seating aggravated his pain and interfered with his ability to sit, stand, walk, sleep, and participate in prison activities.

Roundtree testified that he repeatedly requested a second mattress and special seating. Doctors at Bellevue Hospital and the jail issued referrals for a second mattress, and a Bellevue doctor recommended a higher chair. Roundtree testified that corrections officers repeatedly confiscated the second mattress and chairs. In April 2016, Correctional Health Services adopted a policy prohibiting medical staff from issuing second-mattress referrals, even when a doctor recommended one. The record stated that the policy was based partly on the view that two mattresses had no medical justification and partly on concerns about security and the number of referrals.

Roundtree’s remaining claims included constitutional claims under 42 U.S.C. § 1983, state-law claims, and claims under the Americans with Disabilities Act and the Rehabilitation Act concerning the alleged failure to provide adequate bedding and seating. His separate claims concerning chemical spray were not challenged by this motion. The defendants moved for partial summary judgment on the bedding and seating claims. Roundtree did not file an opposition, but the court independently reviewed the defendants’ evidence because a court may not grant summary judgment solely because the opposing party failed to respond.

Summary-Judgment Standard

Summary judgment is appropriate only when the evidence shows that no genuine dispute exists about a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The court must view reasonable factual inferences in favor of the party opposing the motion. A pro se litigant—someone representing himself without a lawyer—receives some flexibility, but must still provide evidence sufficient to defeat summary judgment.

Timing of the Allegations

The defendants argued that the relevant period ended in March 2016, which would have excluded the April 2016 policy change. The court rejected that argument. It concluded that an earlier order had described the allegations then before the court but had not limited all later bedding and seating allegations to events before March 2016. The Fourth Amended Complaint included later allegations, and the parties had conducted discovery concerning events after March 2016. The court therefore considered those later events.

Constitutional and Medical-Care Claims

The court evaluated the bedding and seating allegations as both conditions-of-confinement claims and claims for denial of adequate medical care. It explained that these claims required evidence that Roundtree had a medical condition requiring special furniture, informed prison officials about the condition, requested the furniture, and was denied it by an official who knew or should have known that the denial posed an excessive risk to his health or safety.

The court found that the record satisfied the requirements needed to defeat summary judgment. Roundtree had medical conditions, received medical referrals for a second mattress and special chair, repeatedly requested the accommodations, filed grievances, and sought assistance from officials and disability advocates. The court rejected the defendants’ argument that pain medication showed that special furniture was unnecessary; it reasoned that the medication could instead show the seriousness of his condition. The court also found evidence that the requested furniture alleviated his pain when provided.

The court rejected the argument that the April 2016 policy conclusively established that a second mattress could never be medically necessary. Roundtree’s testimony indicated that some doctors continued to issue referrals after the policy took effect. The court also found that the evidence about the repeated removal of his chairs could support an inference that the chairs helped him and that the extent of the deprivation could not be resolved on summary judgment.

The defendants argued that corrections officers lacked knowledge of Roundtree’s medical needs. The court found evidence that medical referrals were sent to security staff, that officials sometimes instructed security staff to allow Roundtree to keep the furniture, and that officers could have inferred the medical basis from his condition and his authorized possession of a second mattress. The court therefore concluded that factual disputes remained concerning the constitutional claims.

Municipal Liability

Roundtree also sued the City of New York under § 1983. Municipal liability under that statute requires evidence that a city policy or custom caused the alleged constitutional injury; a city cannot be held liable merely because it employed an individual who allegedly violated the Constitution.

The court found sufficient evidence at the summary-judgment stage of a formal municipal policy: the April 2016 policy prohibited medical staff from issuing second-mattress referrals. Because the defendants did not provide undisputed evidence establishing that the policy did not result in an unconstitutional deprivation, the court rejected their request for summary judgment on the municipal-liability claim.

Americans with Disabilities Act and Rehabilitation Act Claims

The court also denied summary judgment on Roundtree’s disability-discrimination claims. It explained that the Americans with Disabilities Act and the Rehabilitation Act require a plaintiff to show that he has a disability, that the defendant is covered by the relevant statute, and that he was denied access to or discriminated against in connection with an institutional service, program, or activity.

The defendants did not argue that Roundtree was not disabled. Instead, they argued that he had not been denied access to a prison service, program, or activity. The court found evidence from Roundtree’s testimony that the lack of a chair at meals caused physical difficulties and that the lack of a suitable mattress seriously interfered with his ability to function and do things. Those factual disputes prevented summary judgment.

Unnamed Defendants

The court granted the request concerning John Does 1 through 10 and Jane Does 1 through 5. Roundtree had proceeded without a lawyer, but he had received multiple opportunities to amend his complaint, and discovery had closed. The court therefore dismissed those unnamed defendants. It did not dismiss the defendant identified as the Disability Rights Coordinator, referred to in the opinion as Jane Doe #1, because Roundtree had identified that person with reasonable particularity.

Disposition

The court denied the defendants’ motion for summary judgment except with respect to John Does 1 through 10 and Jane Does 1 through 5, whom it dismissed and terminated from the action. The ruling did not decide that Roundtree ultimately would prevail; it held that the evidence presented factual disputes that could not be resolved on summary judgment. The chemical-spray claims were not addressed by this motion.