Barnett v. Rockland County Jail Matnice
- Philip Halpern
- 7:22-cv-02755
- U.S. District Court · Southern District of New York
- 4
In Barnett v. Rockland County Jail Matnice, Judge Halpern dismissed Barnett’s amended conditions-of-confinement complaint for insufficient allegations.
Lafvorne Levi Barnett’s conditions-of-confinement claims were dismissed at the prisoner-case screening stage; the court also denied him permission to proceed without paying fees on appeal.
What happened
In Barnett v. Rockland County Jail Matnice, Lafvorne Levi Barnett alleged that conditions at Rockland County Jail violated his rights. He described mold, bugs, unsafe food, poor ventilation, and effects on his asthma, and sought $8.5 million in damages.
The court had previously told Barnett to add facts showing that the defendants knew about the conditions and a specific serious risk to him, and ignored them. The amended complaint repeated essentially the same allegations and did not explain how the defendants were involved or had the required knowledge.
Judge Philip M. Halpern dismissed the amended complaint during the required screening of a prisoner’s case filed without paying fees. The court declined to allow another amendment, denied fee-waiver status for an appeal after finding an appeal would not be taken in good faith, and directed the Clerk to close the case.
The detailed version
- Barnett v. Rockland County Jail Matnice · No. 7:22-cv-02755
- Philip Halpern
- June 1, 2022
Background
Lafvorne Levi Barnett, proceeding without a lawyer and without paying the filing fee, brought an action concerning conditions during his detention at Rockland County Jail. He alleged that there was mold on the walls of a shower in the “A wing,” mold on a water fountain, bugs in sink drains, food that was not kept warm or safe from COVID-19, inadequate ventilation because windows were bolted shut, and effects on his asthma that caused him to use his asthma machine. He sought $8.5 million in damages in his amended complaint.
The court had previously directed Barnett to amend his complaint because he had not alleged facts showing that the defendants knew about the conditions and a specific risk of serious injury to him, and chose to ignore those conditions and risks. Barnett filed an amended complaint on May 17, 2022.
Screening and analysis
The Prison Litigation Reform Act requires courts to screen complaints filed by prisoners seeking relief from a governmental entity or its employees. The court must dismiss a complaint that is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. Although courts read complaints filed without lawyers liberally, such complaints still must provide enough factual detail to make a claim plausible.
The court found that the amended complaint was essentially the same as the original complaint. It did not state how the named defendants were involved in the alleged conditions or allege facts suggesting that any defendant knew of and ignored the conditions and a specific serious risk to Barnett. The court therefore concluded that the allegations were insufficient to state a conditions-of-confinement claim.
Disposition
The court dismissed the amended complaint under 28 U.S.C. § 1915(e)(2)(B). It declined to give Barnett another opportunity to amend because it determined that the defects could not be cured by further amendment. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied Barnett permission to proceed without paying fees for an appeal. The Clerk was directed to mail Barnett a copy of the order and close the case.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.