Abdullah v. Courtney

CourtDistrict Court, S.D. New York
DecidedApril 15, 2024
Docket1:24-cv-00297
StatusUnknown

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

Bluebook
Abdullah v. Courtney, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ABDUL ABDULLAH, Plaintiff, 24-CV-0297 (LTS) -against- ORDER OF DISMISSAL SERGEANT COURTNEY/30 PCT, et al., Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action under 42 U.S.C. § 1983, alleging that Defendants violated his federal constitutional rights. He sues two officers from the 30th Precinct of the New York City Police Department (“NYPD”): Sergeant Courtney and Captain Jessica Rivera. By order dated February 16, 2024, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth in this order, the Court dismisses this action. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief.

Rule 8 requires a complaint to include enough facts to state a claim for relief “that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if the plaintiff pleads enough factual detail to allow the Court to draw the inference that the defendant is liable for the alleged misconduct. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. After separating legal conclusions from well-pleaded factual allegations, the Court must determine whether those facts make it plausible – not merely possible – that the pleader is entitled to relief. Id.

BACKGROUND Plaintiff states that the events giving rise to his claims occurred on the morning of January 5, 2024, at the NYPD’s 30th Precinct in Manhattan. He alleges that, when he went to retrieve his automobile that had been “illegally impounded” by an unidentified officer at an unspecified time,1 Sergeant Courtney denied him “allodial title after seeing documents of proof

1 Plaintiff has previously filed an action against the NYPD’s 30th Precinct and two police officers in which he alleged that on November 30, 2023, he was falsely arrested and his automobile confiscated. See Abdullah v. NYPD 30th Precinct, ECF 1:24-CV-0137, 1 (LTS) (S.D.N.Y. filed Jan. 7, 2024). In that pending action, on January 29, 2024, the Court directed Plaintiff to amend his claims. ECF 1:24-CV-0137, 4. It is unclear whether the impoundment of Plaintiff’s vehicle that is mentioned in this case is related to the claims in the action under docket number 24-CV-0137. ownership.” (ECF 1, at 4.)2 Plaintiff claims that Defendants committed “malfeasance of duty” and denied him due process of law. He also asserts that the “chain of events cause[d] [him] mental pain, mental anguish, emotional distress[,] fear, anxiety, humiliation[,] [and] loss of enjoyment.” (Id. at 5.) He seeks money damages. DISCUSSION

A. Section 1983 Claims Because Plaintiff alleges that his constitutional right was violated by state officials and seeks money damages, his claims arise 42 U.S.C. § 1983. To state a claim under Section 1983, a plaintiff must allege both that: (1) a right secured by the Constitution or laws of the United States was violated, and (2) the right was violated by a person acting under the color of state law, or a “state actor.” West v. Atkins, 487 U.S. 42, 48-49 (1988). Claims against Sergeant Courtney The Court construes Plaintiff’s allegations that Sergeant Courtney prevented him from retrieving his automobile as attempting to assert a claim that he was deprived of his property in violation of the Fourteenth Amendment. The Due Process Clause of the Fourteenth Amendment protects “against deprivations [of life, liberty, or property] without due process of law.” Rivera-

Powell v. N.Y. City Bd. of Elections, 470 F.3d 458, 464 (2d Cir. 2006) (internal quotation marks and citation omitted). “The fundamental requisite of due process of law is the opportunity to be heard . . . at a meaningful time and in a meaningful manner.” Goldberg v. Kelly, 397 U.S. 254, 267 (1970) (internal quotation marks and citations omitted). Determining whether the process provided is adequate requires a weighing of: (1) the private interest affected; (2) the risk of

2 Plaintiff writes using irregular capitalization. For readability, the Court uses standard capitalization when quoting from the complaint. All other spelling, grammar, and punctuation are as in the original unless otherwise indicated. erroneous deprivation and the probable value of further safeguards; and (3) the governmental interest at issue. See Rivera-Powell, 470 F.3d at 466 (quoting Mathews v. Eldridge, 424 U.S. 319, 335 (1976)). A government official’s random and unauthorized act does not violate a person’s right to procedural due process if a meaningful postdeprivation remedy is available. See Hudson v.

Palmer, 468 U.S. 517, 533 (1986); Parratt v. Taylor, 451 U.S. 527, 540-43 (1981), overruled in part on other grounds by Daniels v. Williams, 474 U.S. 327 (1986); Hellenic Am. Neighborhood Action Comm. v. City of New York, 101 F.3d 877, 880 (2d Cir.

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Bluebook (online)
Abdullah v. Courtney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abdullah-v-courtney-nysd-2024.