Williams, Jr. v. City of New York
- Paul Gardephe
- 1:21-cv-01083
- U.S. District Court · Southern District of New York
- 8
In Williams, Jr. v. City of New York, Judge Gardephe dismissed Williams’s conspiracy claims and some civil-rights claims during required prisoner-complaint screening.
The order affected Alexander Williams, Jr. and the sixteen defendants the Clerk was directed to terminate, including New York City Health & Hospitals Corporation and fifteen named or unidentified individuals. It dismissed Williams’s Sections 1985 and 1986 claims and his Section 1983 claims against eleven defendants.
What happened
Alexander Williams, Jr., representing himself, sued New York City agencies and employees over alleged inhumane conditions and restrictions at the George R. Vierno Center during pretrial detention. He claimed that Command Level Order 370.20, which limited phone calls, visits, showers, commissary access, and recreation during lockdown, violated his constitutional rights.
The court adopted Magistrate Judge Katharine Parker’s recommendation because neither side objected and the court found no obvious error. It dismissed Williams’s claims under federal conspiracy laws, Sections 1985 and 1986, because the complaint did not allege protected-class membership or discriminatory motive and a Section 1986 claim requires a viable Section 1985 claim. It also dismissed Williams’s Section 1983 claims against eleven defendants because the complaint did not adequately explain how they violated his constitutional rights, and it terminated sixteen defendants from the case.
Judge Gardephe entered the order on June 1, 2022. The order dismissed the Section 1985 and 1986 claims and dismissed the Section 1983 claim as to Doctor Bryan Burns, Doctor Saidu Jimoh, Mrs. V, Shawn Fishler, Mr. Roman, Assistant Deputy Warden Lacroix, Captain Ballah, CO Adamchez, CO Edmunds, CO Figurioa, and CO Pierce.
The detailed version
- Williams, Jr. v. City of New York · No. 1:21-cv-01083
- Paul Gardephe
- June 1, 2022
Background
Alexander Williams, Jr. brought the action without a lawyer under Sections 1983, 1985, and 1986 against sixty-six New York City agencies and employees. He alleged that, while he was held for trial at the George R. Vierno Center at Rikers Island, he experienced inhumane living conditions because the facility implemented Command Level Order 370.20. The order established procedures for inmates on court-ordered lockdown and limited access to telephone calls, visits, showers, the commissary, and recreation. Williams alleged that the order violated minimum standards set by the New York City Board of Correction.
The City asked the court to screen Williams’s Second Amended Complaint under federal laws requiring review of prisoner complaints against government entities and employees. The City argued that the complaint did not allege facts showing how numerous defendants violated Williams’s constitutional rights.
Magistrate Judge Katharine Parker recommended dismissing the Section 1985 and Section 1986 claims and terminating sixteen defendants. Neither side filed objections to the recommendation.
Court’s Analysis
Because no objections were filed, Judge Gardephe reviewed the recommendation for obvious error on the face of the record rather than conducting a fresh review of every issue. He found no such error and adopted the recommendation in full.
The court dismissed the Section 1985 conspiracy claim. To state that claim, Williams needed to allege, among other things, that he belonged to a protected class and that the defendants acted because of discriminatory hostility toward that class. The court found that the complaint did not allege that the defendants’ actions were motivated by Williams’s race or another protected characteristic. It also held that being incarcerated, by itself, does not make inmates a protected class for purposes of Section 1985.
The court dismissed the Section 1986 claim as well. Section 1986 provides a claim for failing to prevent a Section 1985 conspiracy, so the court held that Williams could not maintain a Section 1986 claim without a viable Section 1985 claim.
The court also dismissed Williams’s Section 1983 claims against eleven defendants: Doctor Bryan Burns, Doctor Saidu Jimoh, Mrs. V, Shawn Fishler, Mr. Roman, Assistant Deputy Warden Lacroix, Captain Ballah, CO Adamchez, CO Edmunds, CO Figurioa, and CO Pierce. A Section 1983 claim requires facts showing that a person acting under state law deprived the plaintiff of a constitutional right. The court found that the complaint did not provide enough facts showing how these eleven defendants’ conduct deprived Williams of such a right.
Disposition
The court adopted Magistrate Judge Parker’s Report and Recommendation in its entirety. Williams’s claims under Sections 1985 and 1986 were dismissed. Williams’s Section 1983 claim was likewise dismissed as to the eleven defendants identified above.
The Clerk of Court was directed to terminate these sixteen defendants from the action: New York City Health & Hospitals Corporation; Doctor Bryan Burns; Doctor K; Doctor Saidu Jimoh; Mrs. V; Shawn Fishler; Mr. Roman; ADW Lacroix; ESU Captain Ferber; Captain Ballah; ESU Officer Simms; CO Adamchez; CO Edmunds; CO Figurioa; CO Pierce; and Unknown ESU Officer. The order does not state that all of Williams’s remaining claims were dismissed.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.