Singleton v. City of New York

Background

Aaron Singleton, who was incarcerated and litigating without a lawyer, brought this action under 42 U.S.C. § 1983, a federal civil-rights statute. He alleged that, while detained in the custody of the New York City Department of Correction beginning March 17, 2019, his outgoing telephone calls and mail—including legal communications—were turned over to the Bronx County District Attorney’s Office for use in prosecuting him. He also alleged that a prosecutor violated disclosure obligations under Brady v. Maryland and made generalized allegations about his pretrial detention and conditions at Rikers Island. He sought $5 million in damages from the City of New York, the Department of Correction, several correctional and prosecutorial officials, Bronx Supreme Court Justice Ralph Fabrizio, and others.

The court had previously allowed Singleton to proceed without paying the filing fee upfront. It then screened his amended complaint under statutes requiring dismissal of a prisoner’s complaint that is frivolous, fails to state a claim, seeks relief from an immune defendant, or falls outside the court’s jurisdiction.

Rulings on Defendants

The court dismissed the claims against the Department of Correction because, as a City agency, it is not an entity that can be sued. It also dismissed the claims against the City of New York for failure to state a claim. Although the court construed Singleton’s allegations as asserting that the City had a policy or practice of recording detainees’ calls and giving them to prosecutors, it found that his conclusory allegations did not adequately show a City policy, custom, or practice that caused a constitutional violation.

The court dismissed the damages claims against Justice Ralph Fabrizio under judicial immunity. It found that the claims arose from actions and decisions taken while he presided over Singleton’s state-court criminal case. The court also dismissed the claims against the Bronx County District Attorney’s Office, Bronx District Attorney Darcel Clark, and Assistant District Attorneys Allison Kline and Megan Leo under prosecutorial immunity because the claims arose from their prosecution of Singleton. The court treated claims dismissed on immunity grounds as frivolous under the applicable prisoner-fee statute.

The court dismissed the claims against Department of Correction Commissioner Cynthia Brann because Singleton did not allege facts showing her direct and personal involvement in the alleged constitutional violations. The opinion’s discussion does not separately analyze every allegation or every named defendant, including Heidi Grossman.

Constitutional and Prosecution Claims

The court construed the allegations about disclosure of Singleton’s calls and mail as asserting a Fourth Amendment claim. It held that incarcerated people have a reduced expectation of privacy and that Singleton could not reasonably expect his calls or mail to remain private while he was in Department of Correction custody. It therefore dismissed the Fourth Amendment claim for failure to state a claim. The court also held that a breach of attorney-client privilege, by itself, does not create a private damages claim, and that knowingly using a monitored telephone could waive that privilege.

The court construed the mail allegations as First Amendment claims involving access to the courts and mail tampering. It found that Singleton did not allege regular and unjustified interference with his mail, prejudice to a legal proceeding, or harm to his legal representation. It therefore dismissed those claims for failure to state a claim.

The court dismissed Singleton’s Thirteenth Amendment claim challenging his detention because he did not provide facts supporting his assertion that he had been enslaved on Rikers Island. It also dismissed his Section 1983 malicious-prosecution claim under the favorable-termination rule from Heck v. Humphrey. Singleton had been convicted of criminal contempt in the first degree and did not allege that the conviction had been reversed, expunged, declared invalid, or otherwise called into question. The court concluded that success on his claim would necessarily imply that the conviction was invalid.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(i)–(iii), denied Singleton leave to amend further because it found that the defects could not be cured, and denied his motions for summary judgment as moot. It certified that any appeal would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal. The opinion does not state that the dismissal was with or without prejudice.