Holden v. The City Commissioner of NYC Corrections

Background

Charles Holden, who was in the custody of the New York City Department of Correction at the North Infirmary Command on Rikers Island, filed the action without a lawyer. He asserted claims under 42 U.S.C. § 1983, a federal law allowing claims against state or local officials for violating federal rights. The claims concerned excessive force, unlawful searches, and unconstitutional conditions of confinement. The court stated that the complaint could also be read to assert state-law claims. Holden had permission to proceed without prepaying filing fees.

Screening of the Claims Against Supervisory Officials

The Prison Litigation Reform Act required the court to screen the complaint because Holden was a prisoner seeking relief from governmental entities or employees. The court had to dismiss claims that were frivolous, malicious, inadequately pleaded, barred by immunity, or outside the court’s jurisdiction.

The court explained that a § 1983 claim against a supervisory official requires facts showing the official’s own direct and personal involvement in the alleged violation. A supervisor cannot be held liable merely because the supervisor employs or oversees someone who allegedly violated the plaintiff’s rights.

Holden alleged generally that the DOC Commissioner, a Deputy Commissioner, and the wardens of the Eric M. Taylor Center, also identified as C-76, and the Manhattan Detention Complex either created or failed to create policies and practices that led to violations of his rights. The court found that these allegations did not identify what each official personally did or caused, the injury attributable to that conduct, or facts showing the required state of mind. It therefore dismissed Holden’s individual-capacity § 1983 claims against those officials without prejudice to repleading them in an amended complaint that complies with Federal Rule of Civil Procedure 15.

The court also dismissed Holden’s official-capacity claims against the DOC Commissioner, Deputy Commissioner, and the C-76 and MDC wardens because those claims duplicated claims against the City of New York. The court did not add a prejudice qualifier to this part of the disposition.

Unnamed Defendants

The court held that a self-represented litigant is entitled to the court’s assistance in identifying an unnamed defendant. It found that the complaint provided enough information for the New York City Department of Correction to identify the unnamed defendants involved in a July 17, 2023 use-of-force incident near a holding cell at the Manhattan Detention Complex or the Manhattan Criminal Court. The court also found that the information might be sufficient to identify the unnamed defendants involved in searches at C-76 during 2023.

The court ordered the New York City Law Department, as the attorney and agent for the DOC, to determine the identity and badge number of each unnamed defendant Holden sought to sue and provide that information, along with service addresses, to Holden and the court within 60 days. Within 30 days after receiving the information, Holden must file an amended complaint naming the defendants. That amended complaint will replace, rather than supplement, the original complaint, and the court will screen it after filing.

Service and Discovery

The court requested that the City of New York waive service of the summons. It also directed the City to comply with Local Civil Rule 33.2, which requires responses to specified discovery requests in certain prisoner cases, within 120 days after service of the complaint. The court directed the Clerk of Court to send the required materials to Holden and the New York City Law Department.

Disposition

The court dismissed without prejudice Holden’s individual-capacity § 1983 claims against the DOC Commissioner, Deputy Commissioner, and the MDC and C-76 wardens. It dismissed the official-capacity claims against those officials as duplicative of the claims against the City. The court otherwise ordered the identification of the unnamed defendants, requested that the City waive service, and directed the City to provide the required discovery responses. It also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.