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S.D.N.Y.Procedural orderFiled Mar. 18, 2024

Jaime v. New York State Officers

Judge
Ho
Docket
1:24-cv-00266
Court
U.S. District Court · Southern District of New York
Pages
9
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Jaime v. New York State Officers, Judge Ho ordered identification of unnamed court officers and denied permission to appeal without paying fees.

Who this affects

Luis Jaime; the four unidentified court officers he seeks to sue; the New York State Attorney General’s Office, which must identify them and provide service addresses; and the court and Clerk of Court, which must handle the next procedural steps.

What happened

Luis Jaime sued under a federal civil-rights law over events he says occurred in the Manhattan courts on September 30, 2023. He alleges that four unidentified court officers saw him fall down stairs while handcuffed, left him on the floor for an hour, and ignored his requests for medical care.

Because Jaime sued without a lawyer and used unidentified defendants, the court ordered the New York State Attorney General’s Office to determine the officers’ identities and service addresses. The office must provide that information within 60 days. Jaime must file an amended complaint naming the officers within 30 days after receiving the information; that complaint will replace the original one.

Judge Dale E. Ho said the court would screen the amended complaint and address service afterward if necessary. The court also denied Jaime permission to appeal this order without paying fees, finding that an appeal would not be taken in good faith.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Jaime v. New York State Officers · No. 1:24-cv-00266
Judge
Ho
Date
Mar. 18, 2024

Background

Luis Jaime, who the opinion says was incarcerated at Sullivan Correctional Facility, brought the action without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. He alleged that events occurred in the “Manhattan courts” on September 30, 2023. The caption listed New York State Officers and several other generically named defendants. The opinion describes the relevant unidentified defendants as four court officers who allegedly saw Jaime fall down a flight of stairs while handcuffed, left him on the floor for an hour, and ignored his requests for medical attention.

The court had previously granted Jaime permission to proceed without paying the filing fee in advance. The opinion noted that incarcerated people still must pay the full filing fee over time even when that permission is granted.

Identification of Unnamed Defendants

The court applied the rule that a person proceeding without a lawyer is entitled to help from the district court in identifying a defendant. It found that Jaime’s complaint appeared to provide enough information for the New York State Attorney General’s Office—which the opinion identifies as the attorney for and agent of the New York State Unified Court System—to identify the four unnamed court officers and determine where each could be served with the lawsuit.

The order requires the New York State Attorney General’s Office to provide the officers’ identities and service addresses to Jaime and the court within 60 days of the order. Within 30 days after receiving that information, Jaime must file an amended complaint naming the officers. The amended complaint will replace, rather than supplement, the original complaint.

Next Steps and Disposition

After Jaime files the amended complaint, the court will screen it. If necessary, the court may then direct the Clerk of Court to prepare service forms with the defendants’ addresses and send the documents needed for service to the United States Marshals Service.

The court directed the Clerk to mail the order and complaint to the New York State Attorney General’s Office and to mail an information package to Jaime. It also certified that an appeal from the order would not be taken in good faith and denied permission to appeal without paying fees. The order did not decide the merits of Jaime’s civil-rights allegations.

The authoritative version

Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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