Akaniyene William Etuk v. New York City Police Department et al.; Akaniyene William Etuk v. City of New York et al.

District Court, E.D. New York·Decided June 15, 2026·No. 1:24-cv-05180·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------x

AKANIYENE WILLIAM ETUK,

Plaintiff, MEMORANDUM & ORDER 24-CV-5180(EK)(SDE) -against-

NEW YORK CITY POLICE DEPARTMENT et al.,

Defendants.

------------------------------------x AKANIYENE WILLIAM ETUK,

Plaintiff,

MEMORANDUM & ORDER -against- 24-CV-5985(EK)(SDE)

CITY OF NEW YORK et al.,

------------------------------------x

ERIC KOMITEE, United States District Judge:

Akaniyene William Etuk alleges that he was unlawfully arrested and subjected to a forced period of hospitalization. His request to proceed in forma pauperis is granted. 28 U.S.C. § 1915. For the reasons set forth below, plaintiff’s claims are partially dismissed. Background Plaintiff filed two related cases in the Southern District of New York. After the first action was transferred here, he amended the complaint. See Am. Compl. (“5180 Compl.”), No. 24-CV-5180, ECF No. 10. He then filed a second action that was also transferred. See Compl. (“5985 Compl.”), No. 24-CV-

5985, ECF No. 1. Both cases are based on the same events. Plaintiff alleges that in September 2022, police officers entered the apartment he sublet from Corey Copeland and “forcefully and unlawfully” removed him. 5985 Compl. 3-4. He was placed in handcuffs and taken to Brookdale Hospital, where he was forcibly injected with medication. Id. at 4; 5180 Compl. 4. Following his arrest, he contacted Copeland to get back his belongings from the apartment. 5985 Compl. 4-5. Copeland referred him to the police, who denied taking possession of Etuk’s belongings. Id. Plaintiff alleges a violation of his right to privacy,

excessive force, violation of due process, false arrest, false imprisonment, intentional infliction of emotional distress, negligent infliction of emotional distress, and conversion. He seeks monetary damages. Legal Standard A district court will dismiss an in forma pauperis action when the action “(i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B). At this stage, “the court’s task is to assess the legal feasibility of the complaint.” Lynch v. City of New York, 952 F.3d 67, 75 (2d Cir.

2020). In doing so, the court “must take the facts alleged in the complaint as true, drawing all reasonable inferences in [the plaintiff’s] favor.” In re NYSE Specialists Sec. Litig., 503 F.3d 89, 91 (2d Cir. 2007). Pro se complaints are “held to less stringent standards” than pleadings drafted by attorneys, and the court will read a pro se complaint liberally and interpret it to raise the strongest claims it suggests. Erickson v. Pardus, 551 U.S. 89, 94 (2007); Sealed Plaintiff v. Sealed Defendant #1, 537 F.3d 185, 191 (2d Cir. 2008). Still, a pro se plaintiff is not exempt from “compliance with relevant rules of procedural and substantive law.” Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir.

1983). Thus, to survive at this stage, the complaint must plead sufficient “facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Courts “are not bound to accept as true a legal conclusion couched as a factual allegation,” and “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. Discussion

A. Consolidation Courts may consolidate actions that “involve a common question of law or fact.” Fed. R. Civ. P. 42(a). Plaintiff’s two actions are entirely based on the same facts; therefore, consolidation is proper. Johnson v. Celotex Corp., 899 F.2d 1281, 1285 (2d Cir. 1990). The Clerk of the Court is directed to (1) consolidate these actions into the first filed case, No. 24-CV-5180, and (2) mark No. 24-CV-5985 closed. All future filings are to be docketed in No. 24-CV-5180. B. Section 1983 Claims Etuk brings constitutional claims against all defendants, alleging “right to privacy” violations, excessive

force, deprivation of due process, false imprisonment, and false arrest, all which we construe as brought under Rev. Stat. § 1979, 42 U.S.C. § 1983. To state a claim under Section 1983, a plaintiff must allege two essential elements: “(1) that the defendants deprived him of a right secured by the Constitution or laws of the United States; and (2) that they did so under color of state law.” Giordano v. City of New York, 274 F.3d 740, 750 (2d Cir. 2001). The Constitution regulates only the conduct of state actors. Ciambriello v. County of Nassau, 292 F.3d 307, 323 (2d Cir. 2002). A private party will be deemed a state actor only when

“there is such a close nexus between the State and the challenged action that seemingly private behavior may be fairly treated as that of the State itself.” Brentwood Acad. v. Tenn. Secondary Sch. Athletic Ass’n, 531 U.S. 288, 295 (2001). 1. Claims Against the CCRB and EMS The claims against the CCRB and EMS cannot proceed because those bodies are not suable entities. The New York City Charter provides that “all actions and proceedings for the recovery of penalties for violation of any law shall be brought in the name of the City of New York and not that of any agency except where otherwise provided by law.” N.Y.C. Charter ch. 17, § 396. CCRB and EMS are both agencies of the City and therefore not suable. See Carmody v. City of New York, No. 05-CV-8084, 2006 WL 1283125, at *2 (S.D.N.Y. May 11, 2006) (CCRB); Petway v.

City of New York, No. 02-CV-2715, 2005 WL 2137805, at *3 (E.D.N.Y. Sep. 2, 2005) (EMS). Moreover, even if we construe these claims as against the City, they fail as set forth below. Plaintiff’s federal claims against these defendants are thus dismissed. 2. Claims Against the City of New York The claims against the City of New York do not survive. To hold a municipality liable under Section 1983, “a

plaintiff is required to plead and prove three elements: (1) an official policy or custom that (2) causes the plaintiff to be subjected to (3) a denial of a constitutional” or other federal right. Lucente v.

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Akaniyene William Etuk v. New York City Police Department et al.; Akaniyene William Etuk v. City of New York et al., (E.D.N.Y. 2026).

Akaniyene William Etuk v. New York City Police Department et al.; Akaniyene William Etuk v. City of New York et al. (Akaniyene William Etuk v. New York City Police Department et al.; Akaniyene William Etuk v. City of New York et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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