Craft v. New York State Police

Background

Christopher D. Craft, Sr., appeared without a lawyer and sued under 42 U.S.C. § 1983, a federal law allowing claims against state actors for violating constitutional rights. He alleged that New York State Troopers Filipini, McGee, and Schacter, along with other troopers, stopped him during two driving incidents in April and June 2022, removed him from his vehicle, handcuffed him, and took his guns. He also alleged that his hand was broken during one of the stops. In later pleadings, he added claims concerning his criminal proceedings against Justices Jeffrey Battisoni and Christie L. D’Alessio, Court Clerk Yvette Walton, Assistant District Attorney Timothy Pagonis, the Pleasant Valley Justice Court, and “DC Supreme Court.”

The court reviewed the complaint because Craft had permission to proceed without paying the filing fee. That review required dismissal of claims that were frivolous, failed to state a claim, sought money from immune defendants, or fell outside the court’s subject-matter jurisdiction.

Vehicular-stop and injury claims

The court understood Craft’s allegations about the stops as possible Fourth Amendment claims. It explained that police generally need a reasonable, specific basis to suspect criminal activity before making an investigative vehicle stop. The court concluded that the existing allegations appeared to suggest the troopers stopped Craft because he possessed guns in violation of an order of protection, so the allegations did not yet establish an unlawful stop. The court nevertheless granted Craft leave to provide additional facts supporting his claims that the April 17 and June 20, 2022 stops lacked the required suspicion. It also granted leave to provide more facts about the alleged broken hand, including when it happened and which defendant allegedly caused it.

Claims dismissed on immunity grounds

The court dismissed the claims against Justices Battisoni and D’Alessio because judges are generally immune from damages claims for acts taken as part of their judicial responsibilities. It also dismissed the claims against Clerk Walton because court clerks may receive the same protection for discretionary work closely connected to the judicial process.

The court dismissed the claims against ADA Pagonis because the alleged conduct fell within the prosecutor’s official duties and was connected to the judicial phase of a criminal case. It dismissed the claims against the Pleasant Valley Justice Court, referred to as the Pleasant Valley Justice Center in part of the opinion, because the New York State Unified Court System is protected by state sovereign immunity from these claims. Finally, the court dismissed the claims against “DC Supreme Court,” which it understood to mean the United States Supreme Court, because federal sovereign immunity barred the claims.

Leave to amend and other rulings

The court granted Craft leave to file a third amended complaint within 60 days. The new complaint must replace, rather than supplement, the second amended complaint and must repeat any facts or claims Craft wants the court to consider. The court directed him to identify the relevant people, describe what each defendant did, provide approximate dates and locations, describe his injuries, and state the relief he seeks. No summons would issue at that time.

The court denied Craft’s application for appointment of pro bono counsel without prejudice to renewal at a later stage because the case was too early for the court to assess its merits. It also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal. Judge Laura Taylor Swain signed the order.