Campbell v. Annucci

Background

Robert Campbell, who was incarcerated at Sing Sing Correctional Facility and represented himself, sued Anthony Annucci, Joseph Sergeant, and two unidentified officers under 42 U.S.C. § 1983. He alleged that the defendants denied him the opportunity to attend a Jumah prayer service during Ramadan, violating the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act, a federal law protecting religious exercise by people confined in institutions. The court had previously allowed Campbell to proceed without prepaying the filing fee.

The complaint had originally been filed by 30 people incarcerated at Sing Sing. The court had separated their claims into individual cases and explained that each person needed to provide facts about that person’s own experience. Campbell’s complaint, however, was written from the perspective of Byron K. Brown, the lead plaintiff in the original filing. It did not provide facts specific to Campbell.

Screening and Leave to Amend

The court explained that federal law requires screening of complaints filed by incarcerated people against governmental entities or employees. At this stage, a complaint may be dismissed if it is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s jurisdiction. A complaint must provide enough factual detail to make liability plausible, although courts read filings by self-represented parties liberally.

The court described the standards for religious-freedom claims under the First Amendment and the institutional religious-exercise protections under the Religious Land Use and Institutionalized Persons Act. But it did not decide whether Campbell had adequately established a violation under either law. Instead, it held that the complaint lacked allegations about Campbell’s own experience and granted him leave to amend.

The amended complaint must provide facts about, among other things, whether Campbell registered as a Muslim with the New York State Department of Corrections and Community Supervision, requested to attend the April 14, 2023 Jumah service, was denied access, filed a grievance, and previously participated in Muslim religious services or events. It must also identify relevant people and titles, describe what each defendant did or failed to do, give approximate dates and locations, describe injuries, and state the relief sought. The amended complaint will replace the original complaint rather than supplement it. Campbell must file it within 60 days, and no summons would issue at that time. The court warned that failure to comply, absent a showing of good cause, would result in dismissal for failure to state a claim.

Request for Counsel

The court denied Campbell’s motion for appointed counsel without prejudice to renewal at a later date. It said the case was too early for the court to assess its merits and identified the merits, the plaintiff’s efforts to obtain a lawyer, and the plaintiff’s ability to investigate and present the case without help as relevant considerations.

Other Matters and Disposition

The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims because Campbell had been given an opportunity to amend. It also stated that Campbell could consult the New York Legal Assistance Group’s clinic, which is a private organization and not part of the court.

The court granted Campbell leave to file an amended complaint. It denied his request for appointed counsel without prejudice to renewal. It 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. The order was procedural: the court did not reach the merits of Campbell’s religious-freedom claims.