Arroyo v. John/Jane Does 1-4

Background

Annibal Arroyo, who was incarcerated at Shawangunk Correctional Facility and represented himself, brought this action under 42 U.S.C. § 1983 against four unidentified people sued in their individual capacities. He alleged that the defendants were employees of the New York City Department of Correction and Corizon Health and that, while he was detained at the Anna M. Kross Center in 2018 and 2019, they disclosed confidential information from his medical and mental-health records to correction officers.

Arroyo also alleged that some or all of the defendants repeatedly selected him for strip searches, required him to remove his clothing in front of female staff, left him naked in an area he described as not secluded for an extended period, and referred during the searches to his medical and mental-health records and his alleged crimes. He said the searches were intended only to harass him and had no legitimate purpose.

Screening standard and personal involvement

Because Arroyo was a prisoner seeking relief against government-related defendants, the court screened the complaint under the Prison Litigation Reform Act. The court explained that it must dismiss claims that are frivolous, malicious, fail to state a claim for relief, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also said that pleadings filed by people without lawyers are read generously, but they still must provide enough facts to make a claim legally plausible.

The court held that a claim under Section 1983 requires facts showing each defendant’s direct personal involvement in the alleged constitutional violation. Arroyo had described the defendants’ alleged conduct generally but had not identified what each of the four Doe defendants did or failed to do. The complaint also did not make clear whether the defendants were correction officers, medical personnel, or both. The court instructed Arroyo to identify each defendant as specifically as possible and to describe that person’s conduct, including the relevant date, location, and job information.

The court noted that the unidentified defendants might overlap with people named in Arroyo’s earlier related proceedings and that preclusion issues might arise. The court did not decide those issues in this order.

Medical-information claim

The court explained that the Health Insurance Portability and Accountability Act prohibits certain unauthorized disclosures of medical records but does not create a private right for individuals to sue under that statute. The statute therefore could not independently support Arroyo’s claim for relief based on the alleged disclosures.

The court also considered whether the alleged disclosures could violate the Fourteenth Amendment’s protection for confidential medical information. It explained that incarcerated people retain privacy rights that are not inconsistent with incarceration or legitimate correctional objectives. But the complaint did not describe the nature of the medical information, which left the strength of Arroyo’s privacy interest unclear. It also did not describe the circumstances of the disclosures or whether the disclosures had a legitimate correctional purpose. The court therefore concluded that the complaint did not state a Section 1983 claim based on the disclosure of confidential medical information, while allowing Arroyo to provide additional facts in an amended complaint.

Strip-search claim

The court analyzed the alleged strip searches under the Fourth Amendment, which prohibits unreasonable searches. It explained that jail officials may conduct random searches, including of people awaiting trial, without individualized suspicion. However, searches involving intentional humiliation, abuse, or invasive touching may violate the Constitution.

The court found that Arroyo’s allegation that the searches were random did not itself make them unlawful. His statement that the searches lacked a legitimate correctional justification was conclusory, and he did not provide facts showing why the searches were unrelated to legitimate security interests. His statement that he was left naked for an “extended” period did not say whether that meant minutes or hours. He also did not provide enough information about how often the searches occurred, when they occurred, what was said, or what each defendant did. The court concluded that the complaint did not state a Fourth Amendment claim but allowed Arroyo to add those details.

Order

Judge Laura Taylor Swain granted Arroyo leave to file an amended complaint within 60 days. The amended complaint must replace the original complaint rather than merely add to it. It must identify the defendants, state the facts supporting each claim against each defendant, describe the dates and locations of the events, explain the injuries, and state the relief requested. The court explained that using Doe names does not stop the three-year limitations period from running and that Arroyo was responsible for identifying the defendants before that period expired.

The court ordered that no summons issue at that time. It warned that if Arroyo did not timely comply and could not show good cause, the federal claims would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The clerk was directed to mail Arroyo a copy of the order.