Youngs v. Orange County Sherrifs Organization

Background

Robert Youngs, who was incarcerated at Shawangunk Correctional Facility, filed this self-represented action concerning alleged conduct by correctional staff at the Orange County Jail. Because he alleged that state actors violated federal rights, the court treated the complaint as asserting claims under 42 U.S.C. § 1983, a federal law that allows claims for certain constitutional violations by state actors.

Earlier orders had allowed Youngs to amend his allegations concerning disciplinary due process, a retaliatory false misbehavior report, excessive force, and failure to protect. Those orders dismissed the claims against the Orange County Sheriff’s Organization because the entity could not be sued under New York law. They also dismissed claims concerning New York’s Freedom of Information Law and the jail grievance procedure for failure to state a legally sufficient claim. Youngs did not file his amended complaint before the action was dismissed, but the Clerk’s Office received the amended complaint the next day.

Claims and Defendants Added

The court construed the amended complaint as asserting a disciplinary due-process claim against Sergeant Gessner. Youngs alleged that Gessner refused to let him call witnesses at a December 8, 2021 disciplinary hearing. The court directed the Clerk to add Gessner as a defendant under Federal Rule of Civil Procedure 21.

The court also construed the following allegations as retaliation claims:

- Youngs alleged that Officer Riccardo Laudato issued a false misbehavior report on December 2, 2021, after Youngs requested a grievance form. - Youngs alleged that Sergeants Della Pia and K. Mann recommended that he remain in segregated cell confinement because he requested grievance forms.

The court directed the Clerk to add Laudato, Della Pia, and Mann as defendants under Rule 21.

Service and Discovery

Because Youngs had permission to proceed without prepaying the filing fee, the court ordered the Clerk to issue summonses and prepare the paperwork needed for the U.S. Marshals Service to serve Orange County, Gessner, Laudato, Della Pia, and Mann. The court stated that service must occur within 90 days after the summonses are issued, and that Youngs should request an extension if service is not completed within that period.

The court applied Local Civil Rule 33.2 to Orange County and Gessner. That rule requires defendants in certain prisoner cases to respond to specified discovery requests. Those defendants were ordered to serve responses within 120 days after service of the complaint.

Claims Involving Youngs’s Minor Child

Youngs sought relief based on an allegation that Officer Angel Mendoza detained his minor child during a visit on October 30, 2019. The court held that a parent who is not a lawyer cannot represent a child in federal court while representing himself. It therefore dismissed without prejudice the claims Youngs asserted on behalf of his minor child. “Without prejudice” means the dismissal did not permanently bar a properly represented claim.

October 30, 2019 Claims

The court also concluded that it lacked subject-matter jurisdiction, meaning the legal authority to hear the claim, over any claim Youngs was asserting concerning the October 30, 2019 incident. The court explained that Youngs’s allegation of an injury arising from his child’s alleged detention did not state a claim under federal law. It also found that the allegations did not establish the requirements for diversity jurisdiction, including the required citizenship differences and an amount in controversy exceeding $75,000.

The court therefore dismissed any claims Youngs sought to assert against Orange County concerning that incident for lack of subject-matter jurisdiction. It gave him 60 days to request permission to replead those claims by alleging facts showing that the court has diversity jurisdiction over a state-law claim. The order did not decide the merits of the alleged detention.

Other Rulings

The court referred Youngs to the New York Legal Assistance Group for possible limited legal assistance. It also certified that any appeal from the order would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.

Disposition

The order added four individual defendants, ordered service, applied Local Civil Rule 33.2 to Orange County and Gessner, dismissed without prejudice the claims brought on behalf of Youngs’s minor child, and dismissed for lack of subject-matter jurisdiction the claims concerning the October 30, 2019 incident, with 60 days’ leave to request permission to replead. It did not resolve whether the remaining constitutional allegations were ultimately valid.