Cofield v. The Plaza

Background

Rickey Cofield filed the action under the court's federal-question jurisdiction while representing himself. The court had previously allowed him to proceed without prepaying filing fees. Cofield alleged that he was at “the Plaza” or “the Citadel,” which the court said appeared to refer to the Plaza Rehabilitation Center and Nursing Center. He alleged that staff were abusive, neglectful, and antagonistic; that an observation-unit manager bumped his foot; that she called law enforcement after he held his cane; and that police and fire personnel took him to Jacobi Hospital. He further alleged that he was cleared in a psychiatric evaluation, admitted to a medical unit, and often had to ask for food, water, and Tylenol while his room was not cleaned. He identified claims for defamation, “physical abuse,” and “verbal degradation,” but did not clearly identify the relief sought.

Legal standard

Because Cofield was proceeding without prepaying fees, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). Screening requires dismissal of an action, or part of one, that is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also must dismiss claims over which it lacks subject-matter jurisdiction, meaning the court lacks legal power to hear them. Although courts read self-represented complaints generously, the complaint still must provide a short and plain statement with enough factual detail to make a claim plausible.

Section 1983 claims

The court construed Cofield's invocation of federal-question jurisdiction as asserting claims under 42 U.S.C. § 1983. Section 1983 provides a cause of action when a person acting under color of state law—meaning as a state actor—violates a right protected by the Constitution or federal law. A plaintiff must also allege each defendant's direct and personal involvement.

The Plaza/Citadel and the unnamed employee: The court held that the complaint did not contain enough facts to state a Section 1983 claim against either defendant. It was unclear whether they were state actors. Even assuming they were, the allegations that the employee was antagonistic, immature, and ridiculous, bumped Cofield's foot, and called law enforcement after he held his cane did not clearly identify the constitutional violation. The court allowed Cofield to provide additional facts explaining what constitutional rights he believed these defendants violated.

Jacobi Hospital and New York City Health + Hospitals: The court explained that a hospital itself is not a “person” subject to Section 1983 liability, but that Jacobi Hospital is operated by New York City Health + Hospitals, a public benefit corporation that can be sued under Section 1983. Although Cofield did not name Jacobi Hospital as a defendant, the court construed the allegations about the hospital as claims against New York City Health + Hospitals. To state such a claim, Cofield had to allege that a policy, custom, or practice of New York City Health + Hospitals caused a violation of his constitutional rights. The court found that he had not alleged facts showing such a policy, custom, or practice, and allowed him to provide them.

The court also noted that the complaint indicated Cofield had been cleared in the psychiatric evaluation before the events at Jacobi Hospital. The court said it therefore appeared that he was not being held involuntarily and that New York City Health + Hospitals may not have had an affirmative constitutional duty to provide medical treatment on the facts alleged. The opinion did not finally decide that issue because it granted leave to amend.

State-law claims

The allegations could potentially support state-law claims. The court did not decide whether to exercise supplemental jurisdiction, which is a federal court's discretionary authority to hear related state-law claims. It said it would decide that issue later, particularly because it was unclear whether Cofield could state a federal claim within the court's original jurisdiction.

Disposition

Judge Laura Taylor Swain granted Cofield leave to file an amended complaint within 60 days. The amended complaint must include, for each claim and defendant, the relevant people and titles, what each defendant did or failed to do, approximate dates and locations, Cofield's injuries, and the relief requested. It must be labeled “Amended Complaint” and include docket number 22-CV-6584. It will completely replace the original complaint, so any facts or claims from the original complaint that Cofield wants considered must be repeated. No summons would issue at that time.

The court stated that if Cofield did not comply within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.