Trimm v. Greenhaven Corr. Facility

Background

On March 25, 2024, the court received a letter from Dustin J. Trimm, who was incarcerated at Green Haven Correctional Facility. The letter asserted a claim that officials were deliberately indifferent to his serious medical needs and described alleged unconstitutional conditions of confinement. Because the letter appeared to intend civil claims, the Clerk opened it as a new civil action.

On April 8, 2024, however, the court received a complaint from Trimm against the New York State Department of Corrections and Community Supervision and several correctional officials. That complaint arose from the same events described in the letter and was filed under docket number 24-CV-2737.

Court’s reasoning

The court determined that this action, which consisted of Trimm’s letter, had been opened in error. Trimm’s later submission of a proper complaint about the same events showed that he did not intend the letter to begin a separate civil case. The court also found that the claims in the letter duplicated the claims in the other complaint, so continuing this lawsuit would serve no useful purpose.

Ruling

Judge Laura Taylor Swain dismissed the action without prejudice to Trimm’s pending case under docket number 24-CV-2737. The court terminated all other pending matters and directed the Clerk to enter judgment.

The court directed the Clerk not to charge Trimm the $405 filing fee for this action and ordered that funds not be deducted or encumbered from his prison trust account for the lawsuit. The court also certified that any appeal would not be taken in good faith and denied permission to appeal without paying the required fees.