Chabrier v. Martinez

Background

Christopher L. Chabrier, who was detained at the Vernon C. Bain Center, filed this pro se action under 42 U.S.C. § 1983, a federal law allowing claims against state or local actors for certain constitutional violations. He alleged that defendants violated his rights while he was detained at the Anna M. Kross Center and the Vernon C. Bain Center. The opinion states that the court had previously granted his request to proceed without prepaying the filing fee.

The complaint named Correctional Officer Martinez, Correctional Officer Dennis, and Correctional Officer John Doe. Chabrier also alleged that Captain Young and unidentified correctional officers and medical staff were involved in the alleged violations. He further claimed that the New York City Department of Correction was unable to keep inmates safe at Rikers Island because of the pervasive presence of gangs.

Orders concerning the parties and service

Under Federal Rule of Civil Procedure 21, the court directed the clerk to amend the case caption to add:

- the City of New York; - Captain Young; - AMKC John Doe correctional officers 2–3; - AMKC John Doe medical staff members; - AMKC John Doe correctional officers 4–8; - VCBC John Doe correctional officers 1–5; and - VCBC John Doe medical staff members.

The court stated that this amendment was without prejudice to defenses the added defendants might assert. It directed the clerk to notify the New York City Department of Correction and the New York City Law Department. The court requested that the City of New York, Correctional Officer Martinez, Correctional Officer Dennis, and Captain Young waive service of summons.

Identification of John Doe defendants

Because a self-represented litigant is entitled to court assistance in identifying an unknown defendant, the court ordered the New York City Law Department to determine the identities, badge numbers, and service addresses of the unidentified correctional officers whom Chabrier sought to sue. The court separately ordered NYC Health + Hospitals to identify the unidentified medical staff members and provide service addresses. The opinion notes that Chabrier’s medical records indicated that he was likely treated by staff employed by NYC Health + Hospitals or its subcontractor, the Physicians Affiliate Group of New York.

The New York City Law Department and NYC Health + Hospitals were ordered to provide the information to Chabrier and the court within 60 days of the order. Within 30 days after receiving the information, Chabrier was required to file an amended complaint naming the John Doe defendants. The amended complaint would replace, rather than supplement, the original complaint. The court stated that it would screen the amended complaint and, if necessary, issue further service instructions.

Discovery

The court ruled that Local Civil Rule 33.2 applied to the action. That rule requires defendants in certain prisoner cases to respond to specified court-ordered discovery requests. Defendants were ordered to serve responses to the standard interrogatories and document requests within 120 days of the order and to quote each request verbatim in their responses.

Disposition and scope

The court issued an order of service and related procedural directives. It did not decide the merits of Chabrier’s allegations or determine whether any defendant violated his rights. The opinion contains a date inconsistency concerning the VCBC medical-care allegations: one passage refers to May 18–22, 2022, while another refers to May 18–22, 2021.