Maina v. Somerset County Jail

Background

Michelle Maina, who was detained at the Rose M. Singer Center on Rikers Island, filed this self-represented action under 42 U.S.C. § 1983, a federal law allowing claims against persons who violate constitutional rights while acting under state law. She alleged that events occurred in Bridgewater and at the Somerset County Jail in Somerset County, New Jersey, from 2018 to the present. She also named defendants associated with Rikers Island, but the court found that the complaint did not clearly identify any rights-violating event at a Rikers Island facility or elsewhere in the Southern District of New York.

The defendants fell into three groups: defendants located or employed in New Jersey; defendants located or employed in the Southern District of New York; and defendants whose locations, employers, or roles were not adequately identified. The New Jersey defendants included Somerset County Jail, the Bridgewater Police Department, “CFG (medical @ SCJ),” Somerset County Courthouse, several Somerset County Jail correction officers, several CFG nurses, and several Bridgewater police officers. The court treated claims against Sgt. Anthony, Brian Pauli, Sgt. Lai, Officer Kochinski, and former paid lawyer John Hooper as belonging with the Rikers Island claims for purposes of the order, while noting that the complaint did not clearly establish their locations or employment.

Severance and transfer

Federal Rule of Civil Procedure 20 generally permits multiple defendants to be joined in one action only when the claims arise from the same transaction or series of events and share common legal or factual questions. Rule 21 allows a court to sever claims. The court concluded that the claims concerning arrest, detention, and criminal proceedings in Somerset County, New Jersey, were not logically connected to the possible claims concerning Rikers Island. The court therefore severed the two sets of claims.

The court determined that the New Jersey claims arose in Somerset County, which is within the District of New Jersey, and that venue for those claims appeared improper in the Southern District of New York. Under 28 U.S.C. § 1406(a), a court may transfer a case filed in the wrong venue when transfer serves the interests of justice. The court transferred Maina’s claims against the New Jersey defendants to the U.S. District Court for the District of New Jersey. The clerk was directed to terminate those defendants from the Southern District of New York action, without prejudice to litigating the claims against them in the District of New Jersey.

The court declined to transfer the claims against Anthony, Pauli, Lai, Kochinski, and Hooper because the complaint did not make clear whether they lived or worked in New Jersey or whether the claims against them arose there. The order stated that Maina could seek to add those defendants in an amended complaint filed in the District of New Jersey if venue there was proper and the amended complaint complied with Rule 15.

Order to amend the New York claims

The court found that the complaint did not satisfy Rule 8, which requires enough factual detail to make a claim for relief plausible. Although Maina named “Rikers Island Medical & Mental Health” and several Rikers Island officers, she did not allege facts connecting those defendants to a violation of her federal rights. The court therefore granted her leave to file an amended complaint alleging facts supporting a federal claim arising at Rikers Island or elsewhere in the Southern District of New York. The amended complaint must concern only events occurring in that district.

The court also explained that Rikers Island and its “Medical & Mental Health” department are not “persons” that can be sued under Section 1983. If Maina files an amended complaint about Rikers Island events, she must identify the individual Rikers Island or Department of Correction officials who allegedly violated her rights. The court stated that she could also name the City of New York if she alleged facts showing that a city policy, practice, or custom caused the constitutional violation.

Instructions and disposition

The court granted Maina 60 days from the date of the order to submit an amended complaint to the Southern District of New York’s Pro Se Intake Unit. The amended complaint must be labeled “Amended Complaint,” use docket number 23-CV-10783 (LTS), identify each defendant in both the caption and the statement of claim, and describe the relevant events, dates, locations, injuries, and requested relief. The amended complaint will replace rather than supplement the original complaint, so any facts or claims she wants the court to consider must be repeated in it.

No summons would issue at that time. The order stated that if Maina failed to amend within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim, and the court would decline to exercise supplemental jurisdiction over any state-law claims. The court certified that an appeal would not be taken in good faith and denied fee-waiver status for purposes of an appeal. This order transferred and severed claims and allowed amendment; it did not decide the merits of whether the alleged constitutional violations occurred.