Johnson v. Rose M. Singer Center

Background

Jinja “Kyng Pariah” Johnson filed a self-represented action under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority for violating federal rights. She was detained at the Rose M. Singer Center on Rikers Island. Her allegations concerned her arrest, her detention and housing conditions, access to inhaler pumps, alleged poisoning by two other detainees, an alleged attempted kidnapping by Ivanka Trump, stalking by Nicole Arrington, and alleged infringement of her music by Shawn Carter, Beyonce Knowles-Carter, Wiz Kid, Saint Jhn, and Katora Moreró “Young Ma.”

The court screened the complaint under federal prisoner-screening laws. It explained that Johnson had to allege both a violation of a federal right and action by a person acting under state authority. She also had to identify each defendant’s personal involvement; a person generally cannot be held liable merely because that person supervises someone else.

Claims the Court Allowed Johnson to Try to Amend

The court construed Johnson’s allegations about difficulty breathing and housing in mental-health areas as a pretrial-detainee conditions-of-confinement claim under the Fourteenth Amendment. The court found that she had not identified an individual who knew of a specific serious risk to her health or safety and ignored it. She also did not describe the conditions precisely or explain how they affected her health.

The court construed Johnson’s allegation that she lacked enough inhaler pumps as a medical-care claim under the Fourteenth Amendment. It found that she did not allege facts showing that an individual correctional official knowingly or recklessly failed to address an excessive health or safety risk.

The court also construed the allegations about her January 31, 2022 arrest as a possible Fourth Amendment false-arrest claim. It found that stating only that she was arrested after Ivanka Trump allegedly tried to kidnap her was not enough to support that claim. The court also found that the complaint did not provide enough information to determine whether Johnson could state a § 1983 claim against Arrington or Arrington’s uncle, who might be associated with the New York Police Department’s 77th Precinct. The court therefore declined to dismiss the claims against Arrington at that stage.

The court found that Johnson did not allege facts showing that a City of New York policy, custom, or practice caused the alleged constitutional violations. The order’s analysis states that she therefore failed to state a claim against the City, but the conclusion does not list the City among the defendants whose claims were dismissed. The court granted Johnson leave to amend her potentially curable conditions-of-confinement, medical, false-arrest, and stalking claims.

Severance of Music-Infringement Claims

The court severed the claims against Shawn Carter, Beyonce Knowles-Carter, Wiz Kid, Saint Jhn, and Katora Moreró “Young Ma” because those alleged music-infringement claims were unrelated to the claims involving Johnson’s arrest and detention. Under the federal rules governing joinder, unrelated claims against multiple defendants generally cannot proceed in one action. The court directed the Clerk of Court to open a new civil action containing those claims and defendants. The order stated that a new filing fee would apply, subject to Johnson’s opportunity to request waiver of advance payment.

Claims Dismissed

The court dismissed the claims against the New York City Police Department and the Rose M. Singer Center under the New York City Charter because municipal agencies generally cannot be sued separately from the City of New York. The court stated that this dismissal was without prejudice to asserting those claims against the City of New York.

The court dismissed Johnson’s § 1983 claims against Victoria Nasarovia and Suzette Troutman because they were private detainees, not people acting under state authority. It also dismissed without prejudice any state-law claims Johnson might be asserting against them because the court declined to exercise supplemental jurisdiction over those claims.

The court dismissed the claims against the State of New York because the Eleventh Amendment generally bars suits against a state in federal court, and the opinion states that New York had not waived that immunity and Congress had not removed it for § 1983 claims.

The court dismissed the claims against Ivanka Trump as frivolous under the prisoner-screening statute. It found that Johnson offered no plausible facts supporting the alleged attempted kidnapping and described the claim as baseless.

Amendment and Disposition

The court granted Johnson leave to file an amended complaint within 60 days. The amended complaint had to replace the original complaint, identify the people personally involved, describe what each person did or failed to do, provide relevant dates and locations, describe injuries, and state the requested relief. The court warned that if Johnson did not amend on time and could not show good cause, the complaint 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 advance payment of fees.