Wright v. Administration of Children Services

Background

Delilah Candice Wright proceeded without a lawyer and filed the action without prepaying the filing fee. She alleged that, on April 11, 2022, New York Police Department officers wrongfully detained her while she was staying at a family homeless shelter with her children. She said the shelter director falsely stated that she had an untreated mental-health disorder, that she was forcibly taken to a hospital and illegally detained, and that her children were then taken into the custody of the Administration for Children’s Services. She also alleged that the defendants bullied, harassed, and physically, mentally, and sexually abused her and her children.

Wright sued the Administration for Children’s Services, the Department of Homeless Services, the New York Police Department, Good Shepherd Services, the Bronx Family Court, the Bronx Criminal Court, and the Brooklyn Criminal Court. She sought damages, dismissal of criminal charges, supervised visits with her children, and the children’s return home or other changes to their custody arrangements.

Court’s analysis

The court treated Wright’s constitutional claims as claims under 42 U.S.C. § 1983, a law that permits claims against a person acting under state authority who violates federal rights. Because Wright filed without prepaying fees, the court screened the complaint under 28 U.S.C. § 1915. It concluded that the complaint failed to state claims against the named defendants and that some defendants were protected from suit.

State courts. The Bronx County Family Court, Bronx County Criminal Court, and Brooklyn Criminal Court are part of New York State’s court system. The court held that they are state entities protected by the Eleventh Amendment, which generally bars certain federal lawsuits against states and their instrumentalities. The court dismissed the claims against those courts with prejudice and said they should not be included in an amended complaint.

City agencies. The court dismissed the claims against the New York Police Department, the Department of Homeless Services, and the Administration for Children’s Services because those agencies cannot be sued separately from the City of New York. The dismissal was without prejudice to pleading a claim against the City or an individual employee who was personally involved. The court explained that a claim against the City would also require facts showing that a city policy, custom, or practice caused the alleged constitutional violation.

Good Shepherd Services. Wright named Good Shepherd Services but alleged no facts about it in the body of the complaint. The court concluded that she therefore failed to state a claim against that defendant. It further explained that, if she names the organization again, she must plead facts showing that it acted under state authority, because private parties generally are not liable under § 1983.

Custody requests. The court said federal district courts generally abstain from deciding custody and visitation disputes when those matters can be addressed in state court. Wright’s custody matters appeared to be pending in Family Court, and she did not allege that she lacked an opportunity to raise her rights there. The court also stated that a federal district court lacks authority to review or overturn state-court custody judgments.

Criminal prosecution. Wright asked the court to order that her criminal charges be dismissed. The court held that it could not control the prosecutor’s discretionary decision whether to continue a criminal prosecution, and dismissed those claims.

False arrest. The court described the elements of a false-arrest claim under New York law, including confinement without consent that was not legally justified. But Wright sued only the New York Police Department and did not identify an individual officer who was personally involved. Because the department cannot be sued in its own name, she failed to state a false-arrest claim against a named defendant. The court granted leave to amend to identify a personally involved officer, including a John Doe or Jane Doe officer if necessary, and to provide identifying information and facts about the officer’s conduct.

Hospital confinement. Wright’s allegations about being admitted to a hospital did not make clear which defendant she was suing, whether she was medically evaluated, whether she was involuntarily committed, or how long she was detained. The court held that these allegations did not provide the short and plain statement required by the federal pleading rules. It allowed her to replead by identifying a defendant, describing what happened at the hospital, and explaining how her constitutional rights were violated.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii)-(iii), with 30 days’ leave to replead. The court stated that the state courts should not be named in an amended complaint. It also stated that the New York Police Department, the Department of Homeless Services, and the Administration for Children’s Services should not be named, although Wright could plead claims against the City of New York or a personally involved employee under the standards described in the order. If Wright did not amend the complaint or request more time, the clerk would be directed to enter judgment. The court certified that an appeal would not be taken in good faith and denied fee-waiver status for an appeal.