Thompson v. City of New York

Background

Kwaine Thompson, proceeding without a lawyer, sued Warden Renee, Capt. Carter, and the City of New York under a federal civil-rights law and the Religious Land Use and Institutionalized Persons Act. He alleged that, while detained at Rikers Island under court-ordered lockdown, officials denied him access to Muslim congregational services, an imam, a Quran, and exercise. He also alleged that officials failed to provide adequate medical care for several conditions.

The defendants moved to dismiss. Thompson opposed that motion and filed motions seeking summary judgment, but his summary-judgment filings did not include the materials ordinarily required for such a motion. The court considered some additional allegations in a late-filed opposition because Thompson was representing himself, while warning him to follow future deadlines.

Claims Against Warden Renee and Capt. Carter

The court granted the motion to dismiss all claims against Warden Renee and Capt. Carter. For claims under the federal civil-rights law and the Religious Land Use and Institutionalized Persons Act, Thompson had to plausibly allege that each defendant was personally involved in the alleged misconduct. The court found that he did not allege facts showing that either official made or directed the decisions at issue. Merely sending letters to a prison official also did not establish personal involvement. The court directed that both officials be terminated from the docket.

Exercise Claim

The court granted dismissal of Thompson’s claim that officials violated the Eighth Amendment by denying him exercise. Although Thompson alleged that he was kept in lockdown for 23 hours a day and was sometimes restrained during recreation, he did not allege that he lacked an opportunity to exercise inside his cell or that he was denied outdoor exercise for a sufficiently extended period. The court also found that the alleged 10-day denial of out-of-cell exercise was not enough, by itself, to state an Eighth Amendment claim.

Medical-Care Claims

The court granted dismissal of the medical-care claims based on alleged neglect of priapism, asthma attacks, stomach pains, and back pain because the amended complaint did not provide facts showing that Thompson sought treatment or was actually denied adequate care. The court also dismissed the claim concerning symptoms from smoke inhalation, finding that the alleged chest pain, worsened asthma, and mental-health symptoms were not sufficiently severe under the governing standard.

The court denied dismissal of Thompson’s Eighth Amendment claim concerning mpox. Thompson alleged that he contracted mpox, repeatedly reported his symptoms, was not tested or treated despite requesting care, and continued to suffer rashes, blisters, headaches, chills, and fever. The court found that these allegations were sufficient at the dismissal stage to plausibly show both a serious medical condition and officials’ awareness of, and reckless disregard for, the risk posed by untreated mpox. Thompson was permitted to pursue injunctive relief and damages on this claim.

Religious-Liberty and Equal-Protection Claims

The court granted dismissal of Thompson’s First Amendment and Religious Land Use and Institutionalized Persons Act claims based on denial of access to an imam. His allegations did not say, for example, that he had requested to see an imam or identify who denied such a request.

The court denied dismissal of his claim for injunctive relief concerning Muslim congregational services, including Jumu’ah and Eid al-Adha prayers. Thompson plausibly alleged that attending congregational prayer was required by his sincerely held religious beliefs. The court concluded that the lockdown orders, which restricted telephone calls and did not expressly require separating him from other detainees, did not at this stage establish a sufficient justification for denying access to congregational services.

The court also denied dismissal of Thompson’s equal-protection claim concerning access to a Quran. He alleged that officials told him he could possess a Bible but not a Quran, and submitted an internal order that expressly protected access to a Bible for detainees under lockdown without expressly mentioning other religious texts. The court construed his filings as alleging that Muslim detainees were denied the same protected access to religious materials provided to Christian detainees.

The court stated that Thompson could not recover monetary damages for the religious-liberty claims because he alleged only mental or emotional harm. It allowed him to seek injunctive relief concerning access to congregational services and a Quran.

Disposition

Judge Caproni granted the defendants’ motion to dismiss except as to Thompson’s claims concerning failure to provide constitutionally adequate treatment for mpox, denial of access to religious congregations, and denial of access to a Quran; as to those claims, the motion was denied. Thompson’s motions for summary judgment were denied without prejudice. The court declined to issue a certificate allowing an appeal from the portions granting dismissal and denied the ability to appeal without paying the filing fee. The court reinstated the referral to Magistrate Judge Moses for general pretrial management and preparation of reports on any later dispositive motions.

Classification

This is a procedural order under the stated classification convention because the main ruling was on a motion to dismiss, which tests whether claims were adequately pleaded rather than finally deciding liability on the merits.