Bazelais v. Rikers Island Correctional Center

Background

Wilner C. Bazelais Jr., who was incarcerated at Rikers Island and represented himself, filed an action under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by people acting under state authority. He alleged that, after being transported from Attica Correctional Facility to Rikers Island in October 2021, a $500 check issued from Attica’s “spendable fund” was placed in a Rikers property room. He said that, after several requests to retrieve and deposit the check into his inmate account, it became non-negotiable and void.

Bazelais also alleged that correction officials mishandled, withheld, lost, or stole property and legal documents because of abuse, neglect, and poor communication between Rikers officials and the New York State Department of Corrections and Community Supervision. He referred to an ongoing series of alleged deprivations and abuses during detentions at Rikers from 2017 to 2018 and while in the custody of the state corrections department from 2018 to 2021. He sought monetary damages and termination of the staff members involved.

Screening standard

Because Bazelais was a prisoner proceeding without prepaying filing fees, the court screened the complaint under the Prison Litigation Reform Act. The court was required to dismiss claims that were frivolous or malicious, failed to state a legally sufficient claim, sought monetary relief from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that although it had to read a self-represented plaintiff’s allegations liberally, the complaint still had to provide enough facts to make relief plausible.

Claims against Rikers Island

The court dismissed the claims against Rikers Island for failure to state a claim. It held that Rikers Island is a jail operated by the New York City Department of Correction and is not an entity that can be sued under the New York City Charter. The court further noted that neither Rikers Island nor Attica is a “person” subject to liability under Section 1983.

Claims against Attica Correctional Facility

The court dismissed the claims against Attica and its Office of Special Investigations because Attica is operated by the state corrections department, which is an arm of New York State. The court held that Eleventh Amendment immunity protected the facility from Bazelais’s request for monetary relief. It stated that New York had not waived that immunity and that Congress had not removed it when enacting Section 1983. The court therefore dismissed these claims on the grounds that they sought monetary relief from an immune defendant and that the court lacked subject-matter jurisdiction.

Property-deprivation claim

The court separately held that, even if Bazelais had named proper defendants, he failed to state a claim concerning the lost or mishandled property. When state law provides an adequate remedy for the loss of property, the court explained, the loss does not create a federal due-process claim. The court found that Bazelais had not shown that available state remedies were inadequate or inappropriate, and it dismissed the property claim for failure to state a claim.

Unaddressed allegations and leave to amend

The court did not address the merits of Bazelais’s conclusory allegations about a series of abuses during his earlier detentions. It said he had not named proper defendants and had provided no supporting facts. The court stated that the order did not prevent him from filing a new complaint against proper defendants concerning unlawful violations, and it expressed no opinion on the merits of any such complaint.

The court denied leave to amend the complaint because it found that the defects could not be cured by amendment. It dismissed the complaint for failure to state a claim, seeking monetary relief from an immune defendant, and lack of subject-matter jurisdiction. It terminated all other pending matters and denied permission to proceed without paying fees on appeal, certifying that an appeal would not be taken in good faith.