Scott v. Annucci

Background

Clayton Scott brought this self-represented action under 42 U.S.C. § 1983 against Anthony Annucci, identified as Commissioner of the New York State Department of Corrections and Community Supervision, Joseph Sergeant, and two John Doe officers. Scott alleged that the defendants denied him the opportunity to attend a Jumah prayer service at Sing Sing Correctional Facility during Ramadan, violating the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act.

The complaint originally involved 30 incarcerated people and was written from the perspective of Byron K. Brown, identified as the lead plaintiff. The court had previously separated the plaintiffs’ claims into individual cases. Because the complaint did not include facts about Scott’s own experience, it did not explain when Scott was denied prayer, how the denial affected him, or what steps he took to challenge it.

Screening and leave to amend

The court explained that federal law requires screening of complaints filed by prisoners seeking relief from government entities or officials. A court must dismiss claims that are frivolous, malicious, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. Although courts read self-represented complaints generously, the complaint must still provide enough facts to make liability plausible.

The court did not dismiss Scott’s complaint at this stage. Instead, it granted Scott leave to file an amended complaint within 60 days. The court directed Scott to state facts showing, among other things, whether he was registered as Muslim with the corrections department, asked to attend the April 14, 2023 Jumah service, was denied attendance, filed a grievance, and had previously participated in Muslim religious practices. The amended complaint must identify relevant people and titles, describe the events and each defendant’s involvement, identify injuries, and state the relief sought. It will replace, rather than supplement, the original complaint.

Request for counsel

Scott requested appointment of a lawyer. The court denied that request without prejudice because the case was too early for the court to assess its merits. The ruling allows Scott to renew the request later.

State-law claims and related directions

The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims because Scott had been given an opportunity to amend his federal claims. No summons would issue at that time. The court also stated that an appeal from the order would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.

Disposition

The court granted Scott leave to file an amended complaint within 60 days. It denied his request for counsel without prejudice, deferred the jurisdiction decision on any state-law claims, and warned that failure to timely amend without good cause would result in dismissal for failure to state a claim.