Aaron Snyder v. County of Ulster and State of New York

CourtDistrict Court, N.D. New York
DecidedApril 6, 2026
Docket9:25-cv-01784
StatusUnknown

This text of Aaron Snyder v. County of Ulster and State of New York (Aaron Snyder v. County of Ulster and State of New York) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aaron Snyder v. County of Ulster and State of New York, (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

AARON SNYDER,

Plaintiff, 9:25-CV-1784 (MAD/DJS) v.

COUNTY OF ULSTER and STATE OF NEW YORK,

Defendants.

APPEARANCES: OF COUNSEL:

AARON SNYDER Plaintiff, pro se 4519 Ulster County Jail 380 Boulevard Kingston, NY 12401

MAE A. D'AGOSTINO United States District Judge DECISION AND ORDER I. INTRODUCTION Pro se plaintiff Aaron Snyder ("plaintiff") commenced this action by submitting a complaint pursuant to 42 U.S.C. § 1983 ("Section 1983"), with an application to proceed in forma pauperis ("IFP"). Dkt. No. 1 ("Compl."); Dkt. No. 8 ("IFP Application"). The complaint asserted claims related to plaintiff's confinement at Ulster County Jail ("Ulster C.J."). See generally Compl. By Decision and Order filed on March 2, 2026 (the "March 2026 Order"), this Court granted plaintiff's IFP Application and reviewed the sufficiency of the complaint in accordance with 28 U.S.C. § 1915(e)(2)(B) and 28 U.S.C. § 1915A(b). Dkt. No. 9. On the basis of that review, the Court dismissed plaintiff's complaint for failure to state a claim. Id. In light of plaintiff's pro se status, the Court provided plaintiff with an opportunity to amend his complaint. Id. On March 18, 2026, plaintiff filed an amended complaint. Dkt. No. 11 ("Am. Compl.").

II. SUFFICIENCY OF AMENDED COMPLAINT A. Legal Standard The legal standard governing the dismissal of a pleading for failure to state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B) and 28 U.S.C. § 1915A was discussed at length in the March 2026 Order and will not be restated in this Decision and Order. See Dkt. No. 9 at 2-4. B. Summary of Amended Complaint With the amended complaint, plaintiff identifies the following new defendants: Ulster County Sheriff's Office, Ulster County Superintendent, and John/Jane Doe Corrections Officers 1-5.1 See generally Am. Compl. The complaint also includes claims against previously named defendant, Ulster County. See id. The amended complaint does not

include any claims against the State of New York, a defendant previously named in the original complaint.2 See id. Plaintiff "sincerely holds religious beliefs that require him to be baptized. Am. Compl. at 3. Plaintiff made a formal request to be baptized in accordance with his religious faith. Id. Defendants denied plaintiff's request and no "less restrictive alternative" was offered or considered. Id. The denial was based upon Ulster County's established policy of failing to

1 The Clerk of the Court is directed to amend the Docket Report to include these defendants.

2 The Clerk of the Court is directed to amend the Docket Report to terminate this defendant. provide adequate religious accommodations to detainees and a lack of a policy regarding baptism. Id. at 1, 4. Construing the amended complaint liberally3, plaintiff alleges First Amendment free exercise claims and claims pursuant to the Religious Land Use and Institutionalized Persons

Act of 2000, 42 U.S.C. § 2000cc-1 et seq. ("RLUIPA"). See generally Am. Compl. Plaintiff seeks compensatory damages and declaratory and injunctive relief. Id. at 2, 9-10. C. Analysis The law related to personal involvement in Section 1983 actions was discussed in the March 2026 Order and will not be restated herein. See Dkt. No. 9 at 4-5. Plaintiff's claims against defendants must be dismissed for failure to state a claim. While plaintiff was afforded the opportunity to amend his complaint, the pleading includes a recitation of boilerplate legal standards and caselaw related to First Amendment and RLUJIPA claims, but no factual allegations. For instance, the amended complaint lacks dates, times, and information related to when plaintiff requested to be baptized, how or to

whom he filed the request, how many times he requested to be baptized, and what response, if any, he received from defendants. Because plaintiff failed to assert any factual allegations, the complaint fails to provide any defendant with fair notice of the basis of plaintiff's claims. Plaintiff identifies the Superintendent of the Law Enforcement Center and John/Jane Doe Correction Officers as defendants in the caption and list of parties. However, the

3 The Court is mindful of the Second Circuit's instruction that a pleading by a pro se litigant must be construed liberally and interpreted to raise the strongest arguments that it suggests. See, e.g., Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008) ("On occasions too numerous to count, we have reminded district courts" that a pro se plaintiff's pleadings must be construed liberally); Phillips v. Girdich, 408 F.3d 124, 130 (2d Cir. 2005) ("We leave it for the district court to determine what other claims, if any, [plaintiff] has raised. In so doing, the court's imagination should be limited only by [plaintiff's] factual allegations, not by the legal claims set out in his pleadings."); Burgos v. Hopkins, 14 F.3d 787, 790 (2d Cir. 1994) ("[W]e read [a pro se litigant's] supporting papers liberally, and will interpret them to raise the strongest arguments that they suggest."). pleading lacks factual allegations sufficient to plausibly suggest that these defendants were personally involved in any conduct that violated plaintiff's constitutional rights. Thus, the amended complaint fails to state a cognizable claim against them. See Cipriani v. Buffardi, No. 06–CV–0889 (GTS/DRH), 2007 WL 607341, *1 (N.D.N.Y. Feb. 20, 2007) (“Dismissal is

appropriate where a defendant is listed in the caption, but the body of the complaint fails to indicate what the defendant did to the plaintiff.”) (citation omitted); see also Casino v. Rohl, No. 14-CV-2175, 2014 WL 5425501, at *6 (E.D.N.Y. Oct. 23, 2014) (dismissing complaint since the plaintiff had not adequately pled the defendant's personal involvement in any of the constitutional deprivations alleged in the amended complaint). With the amended complaint, plaintiff addresses Monell and alleges that the wrongful acts occurred pursuant to a policy or custom of Ulster County. See generally Am. Compl. However, in the absence of an underlying constitutional violation, there can be no claim for municipal liability. See, e.g., Segal, 459 F.3d at 219 (noting that once a "district court properly [finds] no underlying constitutional violation, its decision not to address the municipal

defendants’ liability under Monell [is] entirely correct"); Henry-Lee v. City of New York, 746 F. Supp. 2d 546, 567 (S.D.N.Y. 2010) ("[A] prerequisite to municipal liability under Monell is an underlying constitutional violation by a state actor."). "[P]laintiff cannot rely on a group pleading against all defendants without making specific individual factual allegations." 5465 Route 212, LLC v. New York State Dep't of Transportation, No. 1:19-CV-01510 (BKS/DJS), 2020 WL 6888052, at *9 (N.D.N.Y. Nov. 24, 2020); see also Lawson v. Ruskin, No. 08-CV-321, 2008 WL 1902218, at *2 (E.D.N.Y. Apr.

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Related

Sealed v. Sealed 1
537 F.3d 185 (Second Circuit, 2008)
Henry-Lee v. City of New York
746 F. Supp. 2d 546 (S.D. New York, 2010)
Simmons v. Abruzzo
49 F.3d 83 (Second Circuit, 1995)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)
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10 F. App'x 33 (Second Circuit, 2001)
Phillips v. Girdich
408 F.3d 124 (Second Circuit, 2005)

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Aaron Snyder v. County of Ulster and State of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aaron-snyder-v-county-of-ulster-and-state-of-new-york-nynd-2026.