Morris v. The City of New York

Background

Dwayne Morris, representing himself, sued the City of New York under 42 U.S.C. § 1983 and state law. Morris alleged that he was a pretrial detainee on Rikers Island, tested negative for COVID-19 when admitted on October 27, 2020, and later tested positive in May 2021. He alleged that he experienced mild respiratory failure, shortness of breath, fever, chest pains, severe headaches, and difficulty sleeping. He also alleged that, after testing positive, he was placed in a 14-day quarantine in a mobile structure with poor air circulation.

Morris described COVID-19 infections and deaths at the facility and alleged that he tried to obtain medical care but was told he had an appointment at Bellevue Hospital and was then made to miss it. The court construed his amended complaint as asserting two federal claims under § 1983: one concerning conditions of confinement and one concerning inadequate medical care. Although the amended complaint referred to several constitutional amendments, the court treated the claims as arising under the Fourteenth Amendment because Morris was a pretrial detainee.

The City moved to dismiss the first amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. Morris did not oppose the motion.

Court’s Analysis

For a claim against a municipality under § 1983, a plaintiff must allege that a municipal policy or custom caused the violation of a constitutional right. The court referred to this requirement as municipal liability under Monell. A plaintiff may identify an official rule, a practice so widespread that it functions like a rule, or facts showing approval by senior officials.

Conditions of Confinement

The court granted the motion to dismiss the conditions-of-confinement claim because the amended complaint did not adequately allege municipal liability. The complaint appeared to identify two possible practices: housing symptomatic and asymptomatic detainees together, and using a 14-day quarantine policy. But it did not clearly describe what those practices were, how they violated the Constitution, or whether the mixed-housing practice was an official policy or a sufficiently widespread custom.

The court also found the allegations about the quarantine policy unclear. The complaint did not establish whether Morris was asymptomatic when he tested positive and was housed with symptomatic detainees, whether symptomatic detainees were released into the general population after 14 days even if they remained contagious, or whether some other problem with the policy created the alleged risk. The court explained that more facts were needed to show both a constitutional violation and a direct connection between that violation and a City policy or custom.

Inadequate Medical Care

The court also granted the motion to dismiss the inadequate-medical-care claim. Morris’s allegation that he was prevented from attending an appointment could potentially describe a denial of medical care, but the complaint did not identify a City policy or custom causing that denial. It also did not provide enough facts about when the denial occurred, what injuries resulted, or who was responsible. The court stated that a single unconstitutional incident generally does not establish municipal liability unless the incident was caused by an existing unconstitutional municipal policy.

State-Law Claim

The original complaint asserted a gross-negligence claim under state law. After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning it declined to hear the related state-law claim in the same federal case.

Disposition and Leave to Amend

The court granted the City’s motion to dismiss. Because Morris was representing himself and the court could not rule out the possibility that an amended complaint might state a claim, it gave him a final opportunity to file a second amended complaint. The court instructed that any new complaint must allege facts showing an official City policy or practice, a violation of Morris’s constitutional rights, and a causal connection between the policy or practice and that violation. It also explained the facts needed to support deliberate-indifference claims concerning confinement conditions or medical care. Morris was permitted to identify unknown individual defendants as “John Doe” or “Jane Doe” while describing what each person allegedly did.

The court directed Morris to mail a proposed second amended complaint and an explanatory letter to the court’s Pro Se Intake Unit by July 29, 2022.