Stewart v. Medina

Background

Gary A. Stewart, proceeding without a lawyer and without paying filing fees, brought claims under 42 U.S.C. § 1983, a federal civil-rights statute, against G. Medina and the State of New York. Stewart identified Medina as a correction officer at Sing Sing Correctional Facility and alleged that Medina was deliberately indifferent to a serious risk to Stewart’s safety, violating the Eighth Amendment.

Stewart alleged that on May 9, 2020, Medina opened Stewart’s cell, even though the cell was not supposed to be opened that day. Another incarcerated person entered the cell and slashed Stewart with a weapon, causing serious injuries. Stewart also alleged that he had asked that his cell remain closed because he feared contracting COVID-19.

Stewart originally filed the action in the Northern District of New York. The case was later transferred to the Southern District of New York. After the court allowed Stewart to amend his complaint, he filed an amended complaint adding New York as a defendant.

Court’s Analysis

The court explained that federal courts must dismiss a case when they lack subject-matter jurisdiction, meaning the court lacks legal authority to hear the dispute. The court also noted that it must read filings by people without lawyers liberally, while recognizing that federal courts have limited jurisdiction.

The court applied the Eleventh Amendment, which generally protects states from being sued in federal court. The court stated that New York had not waived that immunity and that Congress had not removed it for claims brought under Section 1983. The immunity covered Stewart’s claims for money damages, injunctive relief, and retrospective declaratory relief against New York.

The court therefore dismissed all of Stewart’s claims against the State of New York for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and for lack of standing. The order did not dismiss the claims against G. Medina.

Disposition

The court dismissed all claims against the State of New York and instructed the Clerk to terminate New York as a defendant. It ordered G. Medina to file an answer or otherwise respond to the amended complaint by December 5, 2023.

The court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied Stewart permission to proceed without paying appeal fees. The opinion does not state whether the dismissal of New York was with or without prejudice.