Williams v. The City of New York

Background

Ronald Williams, who was incarcerated at Mid-State Correctional Facility, began this case by sending the court a letter with attached forms. The court received another letter later and treated both letters and their attachments as one complaint. The filings were difficult to understand. Williams appeared to mention problems with jail medical care, conditions at the facility, his conviction in Queens County, and a request for release. The court understood him to have named the City of New York as a defendant and to possibly be asserting claims under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state actors for violations of federal rights.

The court had previously allowed Williams to proceed without paying the filing fee in advance. It noted that incarcerated people must still pay the full filing fee over time under the applicable statute.

Possible request for release

The court explained that if Williams was challenging the imposition or execution of his Queens County state-court sentence, or seeking release from his current incarceration, the proper federal procedure was a petition for a writ of habeas corpus under 28 U.S.C. § 2254. The present submissions did not constitute such a petition. Because the conviction occurred in Queens County, the court stated that the appropriate federal venue for that request would be the Eastern District of New York. If Williams filed an amended § 2254 petition, the court would transfer it there.

Possible civil-rights claims

The court explained that a challenge to confinement conditions should be brought through a civil complaint under § 1983 rather than a release petition. Such a complaint must allege both a violation of a right protected by federal law or the Constitution and action by a person acting under state authority. Claims against individual defendants would require facts showing each person’s direct and personal involvement. Claims against a municipality would require facts showing that a municipal policy, custom, or practice caused the alleged violation.

The court also explained that § 1983 claims must satisfy federal venue rules. Williams was directed to provide facts showing why the Southern District of New York was a proper venue for any claims based on conditions at Mid-State Correctional Facility, which the opinion states is in Oneida County, within the Northern District of New York. If he filed such claims without showing why the Southern District was proper, the court would transfer them to the Northern District of New York.

Ruling

The court granted Williams 60 days to file either an amended § 2254 petition or an amended § 1983 civil complaint. If he failed to comply or failed to show a reason excusing the failure, the court would dismiss the action without prejudice. The court stated that the submissions did not make a substantial showing that a constitutional right had been denied, so it would not issue a certificate of appealability. It also certified that an appeal would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal. The order was signed by Chief United States District Judge Laura Taylor Swain.