Singleton v. Bragg

Background

Dwayne Singleton, who was incarcerated and represented himself, brought an action seeking damages for alleged violations of his federal constitutional rights. The court understood the complaint to assert claims under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state or local actors for constitutional violations, as well as state-law claims. The defendants were New York County District Attorney Alvin Bragg; the City of New York; the New York City Department of Correction; the New York City Police Department’s Midtown North Precinct; and two unidentified police officers.

The court had previously allowed Singleton to proceed without paying the filing fee in advance. Under the prisoner-complaint screening rules, the court was required to dismiss claims that were frivolous, failed to state a legally sufficient claim, or sought damages from an immune defendant.

Rulings

Department of Correction and Midtown North Precinct

The court dismissed all of Singleton’s claims against the Department of Correction and the Midtown North Precinct for failure to state a claim on which relief may be granted. The court held that these entities are subdivisions of New York City and cannot be sued separately. The court stated that this dismissal was without prejudice to Singleton’s claims against the City of New York; it did not dismiss the City on this ground.

District Attorney Bragg

The court dismissed Singleton’s claims under Section 1983 against District Attorney Bragg. The claims concerned Bragg’s decisions and actions in prosecuting Singleton, including alleged advocacy against access to a diversion program. The court held that prosecutors have absolute immunity from damages suits for actions within their official duties that are closely connected to the judicial phase of a criminal case. It therefore dismissed the Section 1983 claims because they sought monetary relief from an immune defendant and were legally frivolous under the prisoner-screening statute.

The opinion does not state a separate disposition for any state-law claims against Bragg.

Unidentified police officers

The court found that the complaint provided enough information for the City’s Corporation Counsel to identify the two unidentified officers. The officers were described as members of the Midtown North Precinct who allegedly arrested Singleton on or about March 20, 2022, near the intersection of 54th Street and 12th Avenue in New York City. The court ordered the Corporation Counsel to provide their identities, badge numbers, and service addresses to Singleton and the court within 60 days.

Within 30 days after receiving that information, Singleton must file an amended complaint naming the officers. The amended complaint will replace, rather than supplement, the original complaint. The court will screen the amended complaint and, if necessary, issue a further order for service.

New York City and service

The court directed the Clerk of Court to issue a summons for the City of New York and send the necessary documents to the U.S. Marshals Service so the City can be served. The court extended the service period to 90 days after the summons is issued. The order also required Singleton to notify the court of any address change.

Disposition

Judge Katherine Polk Failla dismissed Singleton’s claims against the Department of Correction and the Midtown North Precinct for failure to state a claim, and dismissed his Section 1983 claims against Bragg because Bragg was immune from the requested damages and the claims were frivolous. The court ordered information about the unidentified officers, directed service on the City of New York, and required a later amended complaint naming the officers. The court certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.