Crane v. Annucci
- Laura Swain
- 1:23-cv-06912
- U.S. District Court · Southern District of New York
- 19
In Crane v. Annucci, Judge Swain granted leave to amend a prisoner’s religious-rights complaint and denied appointed counsel without prejudice.
Michael A. Crane, a self-represented incarcerated plaintiff, must file an amended complaint within 60 days and provide facts about his own alleged denial of religious worship. His request for appointed counsel was denied without prejudice. The named and unidentified prison-official defendants remain parties while the court awaits the amended complaint.
What happened
In Crane v. Annucci, Michael A. Crane, who was incarcerated at Sing Sing Correctional Facility, sued prison officials under a federal civil-rights law. He alleged that he was denied the opportunity to attend a Jumah prayer service during Ramadan, violating constitutional religious protections and a federal religious-exercise law. The complaint, however, was written from the perspective of another prisoner, Byron K. Brown, and did not describe Crane’s own experience.
The court explained that a prisoner’s complaint must include enough specific facts to plausibly show that each defendant violated the prisoner’s rights. Because Crane’s complaint did not say when he was denied the service, how he was affected, or what steps he took afterward, it did not provide the required facts about his claims. The court also considered, but did not reach a final decision on, any state-law claims because Crane was being allowed to amend his federal claims.
Judge Laura Taylor Swain granted Crane 60 days to file an amended complaint, which would replace the original complaint. The court denied his request for appointed counsel without prejudice, meaning he may renew it later, and denied permission to appeal without prepaying fees. The court warned that failure to amend on time could result in dismissal for failure to state a claim.
The detailed version
- Crane v. Annucci · No. 1:23-cv-06912
- Laura Swain
- Oct. 4, 2023
Background
Michael A. Crane, who was incarcerated at Sing Sing Correctional Facility, filed this self-represented action under 42 U.S.C. § 1983. He alleged that Anthony Annucci, Joseph Sergeant, and two unidentified officers denied him the opportunity to attend a Jumah prayer service during Ramadan. He asserted claims under 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 original complaint was filed by 30 incarcerated individuals and was written from the perspective of Byron K. Brown, identified as the lead plaintiff. The court had previously separated the individuals’ claims into separate cases and instructed each person to provide facts about that person’s own experience. The complaint in Crane’s case did not include facts specific to Crane.
Screening standard
Because Crane was a prisoner proceeding without prepaying filing fees, the court was required to screen the complaint. The court explained that it must dismiss a complaint, or part of one, if it is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. Although courts read self-represented complaints liberally, the complaint still must provide a short and plain statement with enough factual detail to make liability plausible.
Religious-rights allegations
The court described the standards for Crane’s religious-rights claims. A First Amendment free-exercise claim requires facts showing significant interference with the person’s religious beliefs. Under the Religious Land Use and Institutionalized Persons Act, the government generally may not substantially burden an institutionalized person’s religious exercise unless the burden serves a compelling governmental interest through the least restrictive means.
The court did not decide whether Crane’s religious-rights claims were ultimately valid. Instead, it found that the complaint lacked factual allegations about Crane’s own experience and how any defendant violated his rights. The court directed Crane to provide facts, among other things, about whether he registered as Muslim with the Department of Corrections and Community Supervision, asked to attend the April 14, 2023 Jumah service, was denied attendance, filed a grievance, and previously participated in Muslim religious activities.
Leave to amend
The court granted Crane leave to file an amended complaint within 60 days. The amended complaint must replace, rather than supplement, the original complaint. It must identify the relevant people, describe what each defendant did or failed to do and when and where it occurred, describe Crane’s injuries, and state the relief he seeks. The court stated that no summons would issue at that time. It warned that if Crane did not comply within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim.
Request for counsel
The court denied Crane’s motion for appointed counsel without prejudice to renewal at a later date. It reasoned that the case was too early for the court to assess its merits, which was the most important factor in deciding whether counsel should be appointed.
Other rulings
Because Crane was granted leave to amend, the court postponed deciding whether to exercise supplemental jurisdiction over any state-law claims. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The order did not dismiss the complaint at that time; it granted leave to amend and set a deadline for doing so.
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.