Lucas v. House

Background

Troy Lucas, who was housed at Manhattan Psychiatric Center, filed a petition under 28 U.S.C. § 2254, a procedure for challenging custody based on a state-court conviction or sentence. He named Odyssey House as the respondent. Lucas completed almost none of the form’s identifying information: he did not provide the name of the conviction, the court that entered it, or other information about the judgment, and he did not specify the relief sought.

Lucas identified two grounds: he said that Odyssey House overcharged him $7,512 for rent between July 7, 2013, and June 1, 2015, and that he was repeatedly hospitalized “for no apparent reason.” He also referred to “due process” and the “Dred Scott decision” without further explanation.

Habeas ruling

The court explained that federal habeas relief under § 2254 is available only to a person in custody under a state-court judgment and who claims that the custody violates federal law. The court concluded that Lucas did not identify the conviction he challenged or allege facts showing that he was in custody because of a conviction. The court considered the possibility that Odyssey House treatment had been required in connection with a criminal matter, but found no indication that Lucas’s current confinement at Manhattan Psychiatric Center was related to that matter or to his time at Odyssey House.

The court therefore denied the § 2254 petition for lack of jurisdiction. The order’s title describes the matter as dismissed with leave to replead, while the conclusion states that the petition is denied for lack of jurisdiction.

Possible damages claim

The court stated that, to the extent Lucas sought money damages for events at Odyssey House, he would need to pursue that relief under 42 U.S.C. § 1983, a statute allowing claims for violations of federal rights by a person acting under state law. The court found that Lucas had not alleged facts showing a viable § 1983 claim or that Odyssey House acted under state law. It also noted that the alleged events occurred from 2013 through 2015, indicating that such a claim appeared untimely under New York’s three-year limitations period for § 1983 claims.

Leave to amend and other dispositions

Because Lucas was representing himself, the court granted him 30 days to amend his pleading and provide details supporting his claims. He was directed to submit an amended pleading to the court’s Pro Se Intake Unit, label it “Amended Petition,” and use docket number 22-CV-9206 (LTS). The court stated that no response from Odyssey House was required at that time. It further stated that if Lucas failed to correct the deficiencies or comply within the allowed period without showing good cause, the Clerk would be directed to enter judgment.

The court held that Lucas had not made a substantial showing that a constitutional right had been denied, so it would not issue a certificate of appealability. It also certified that an appeal would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal.