Hussey v. Beth Israel Medical Center

Background

Yessuh Suhyes Hussey, who was detained at the time of the order, brought the action without a lawyer under 42 U.S.C. § 1983. The defendants were Beth Israel Medical Center; two unidentified New York City Police Department officers; an unidentified hospital physician; and an unidentified ambulance driver. The case had been transferred from the Eastern District of New York.

Hussey alleged that, on March 21, 2021, New York City police officers acted with bias and prejudice, and that a hospital physician diagnosed him with bipolar disorder. He claimed defamation, mental cruelty, and lost wages. He sought the release of information sealed by statute or court order and protection from what he described as discrimination and false narratives.

Court’s analysis

The court screened the complaint under the Prison Litigation Reform Act and the rules governing complaints filed without prepaying fees. A complaint must contain enough factual detail to make a claim plausible, although courts must read filings by self-represented litigants liberally.

To state a claim under Section 1983, a plaintiff must allege both a violation of federal rights and action by a person acting under state law. The court held that Beth Israel Medical Center was a private hospital and therefore was not a state actor on the allegations presented. Hussey consequently failed to state a Section 1983 claim against the hospital.

The court treated Hussey’s allegations as possibly asserting false arrest based on being taken by police to a hospital. A false-arrest claim requires facts showing, among other things, that the confinement was not legally justified. In the mental-health context, police may take a person into custody when they have reasonable grounds to believe the person is mentally ill and likely to cause serious harm to themselves or others. The court held that Hussey’s reference to police bias and his hospitalization did not provide enough context or facts showing that the officers lacked probable cause, meaning a reasonable legal basis for the arrest.

Because the federal claims were dismissed, the court declined to exercise supplemental jurisdiction, which is the court’s authority to hear related state-law claims, over any state-law claims Hussey may have intended to assert.

Disposition

The court dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). It granted Hussey 60 days to file an amended complaint. The court instructed him to identify the people involved, describe what each person did, provide relevant dates and locations, state his injuries, and specify the relief sought. The amended complaint would replace the original complaint rather than supplement it.

The court also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal. The opinion does not state that the dismissal was with or without prejudice.