Johnson v. Rikers Island

Background

Jinja “KYNG PARIAL” Johnson filed this action without a lawyer and received permission to proceed without paying the filing fee upfront. She alleged that she was denied medical treatment at the Rose M. Singer Center on April 3, 2022, after another inmate allegedly fell on her back while she was bent over. She also alleged that JetBlue Airlines and the United States were involved in denying her access to a fully paid flight in Florida in late 2016 or early 2017 because of facial tattoos. She asserted additional claims involving the “KKK” and alleged kidnapping, detention in detox, and sexual assault in Georgia, but did not provide sufficient details about those events.

Rulings on the Defendants

The court dismissed the claims against Rikers Island, RMSC because that facility is not a suable entity under the New York City Charter. The court construed Johnson’s complaint as intending to sue the City of New York, directed the Clerk to replace Rikers Island, RMSC with the City, and stated that the amendment was without prejudice to defenses the City might assert.

The court dismissed the claims against the United States for lack of subject-matter jurisdiction and because the United States was immune from the monetary relief Johnson sought. The court dropped the claims against JetBlue, the “KKK,” and the Georgia-related claims under Federal Rule of Civil Procedure 21 because they were improperly joined with the RMSC claims. Those claims were dropped without prejudice, and the court said Johnson could bring them in a separate action in the proper forum.

The court dismissed the claims against Isaiah Rashad, Aubrey Graham (“Drake”), Donald Trump, Jr., Mike Pence, Saint Jha, Wiz Kid, and Boosie because Johnson alleged no facts showing their involvement in violating her rights. Leave to amend was denied as to Donald Trump, Jr. and Mike Pence because amendment would be futile. The claims against Rashad, Drake, Saint Jha, and Wiz Kid were dismissed without prejudice to claims Johnson may be pursuing in an earlier related proceeding identified by docket number 22-CV-2410.

Medical-Care Claim and Amendment

The court treated Johnson’s alleged denial of medical care as a claim under 42 U.S.C. § 1983, which permits suits for certain violations of federal rights by state or local actors. Because Johnson was alleged to be a pretrial detainee, the court analyzed the claim under the Fourteenth Amendment. It explained that Johnson needed to allege facts showing a sufficiently serious medical condition and that an individual correctional official intentionally or recklessly failed to take reasonable steps despite knowing, or having reason to know, of an excessive risk to her health or safety.

The court found that Johnson had not identified an individual correctional official or alleged facts showing that such an official failed to act with the required level of disregard for a medical risk. The court therefore granted Johnson leave to file an amended complaint asserting the medical-care claim against the City of New York. The amended complaint had to identify the people involved, describe their actions or failures to act, provide approximate dates and locations, describe injuries, and state the relief sought. It would replace the original complaint rather than supplement it.

Disposition

Judge Laura Taylor Swain dismissed the claims against Rikers Island, RMSC, the United States, and the listed individual defendants; dropped the JetBlue, “KKK,” and Georgia claims without prejudice; substituted the City of New York for Rikers Island, RMSC; and granted leave to amend the medical-care claim against the City. Johnson was ordered to file the amended complaint within 60 days. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.