Young v. Carter
- Vyskocil
- 1:21-cv-08973
- U.S. District Court · Southern District of New York
- 6
In Young v. Carter, Judge Vyskocil dismissed Young’s complaint without prejudice because he had not exhausted prison grievance procedures.
Jason Young’s amended complaint was dismissed without prejudice, the defendants’ motion to dismiss was granted, and the case was closed.
What happened
In Young v. Carter, Jason Young, representing himself, alleged that correction officers at Rikers Island denied him basic toiletries, pepper-sprayed him, and withheld food and water after he complained. The defendants asked the court to dismiss his constitutional-rights claims.
The court found that Young sued only seven days after the incident, leaving too little time to complete the required prison grievance process. Because the failure to exhaust was clear from the complaint, the court dismissed the case without deciding whether the alleged treatment violated the Constitution.
Judge Mary Kay Vyskocil granted the defendants’ motion to dismiss and dismissed Young’s amended complaint without prejudice. The court also directed the Clerk of Court to close the case and pending motions.
The detailed version
- Young v. Carter · No. 1:21-cv-08973
- Vyskocil
- Mar. 9, 2023
Background
Jason Young filed this action without a lawyer against officials identified as Warden Carter, Captain Guerra, Captain Horton, and “Captain John Doe.” Young alleged that, while he was a pretrial detainee at Rikers Island, he and other detainees went without toilet paper, soap, and toothbrushes for two or three days. After they complained, Young alleged that they were pepper-sprayed and denied food, water, and a working toilet for seven or eight hours. He alleged physical and psychological harm and claimed violations of the Eighth and Fourteenth Amendments.
The original complaint was filed as part of a group complaint by 25 plaintiffs. The court separated the plaintiffs’ claims into individual cases. Young later filed an amended complaint that was substantially similar to the original complaint but added the allegation about pepper spray.
Motion to Dismiss
The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not adequately state a legal claim. They argued that Young had not completed the required prison grievance process and that, regardless, his allegations did not plausibly show a constitutional violation. Young filed only a short letter stating that he opposed the motion.
The Prison Litigation Reform Act requires incarcerated people to complete available prison grievance procedures before bringing lawsuits about prison conditions. At Rikers Island, the applicable grievance program required several steps, including submitting a complaint and, if necessary, appealing through several levels of review. The court explained that completing the process could take several weeks.
Court’s Analysis
The court concluded that Young’s failure to complete the grievance process was apparent from the face of his complaint. Young alleged that the incident occurred on October 5, 2021, but he began this lawsuit on October 12, 2021—only seven days later. The court determined that this was too short a period for him to have completed all required grievance steps and received a final decision.
Because the complaint showed that Young had not exhausted available administrative remedies, the court granted the defendants’ motion to dismiss. The court did not address the defendants’ alternative argument that Young had failed to allege a constitutional violation.
Disposition
Judge Mary Kay Vyskocil ordered that the amended complaint be dismissed without prejudice. The Clerk of Court was directed to close the case and all pending motions and mail the order to Young. The opinion does not decide whether the alleged denial of toiletries, pepper spraying, or denial of food and water violated the Constitution.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.