Arafa v. New York State

District Court, E.D. New York·Decided May 2, 2023·No. 1:22-cv-04475·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------x HOSSAM ARAFA,

Plaintiff, MEMORANDUM & ORDER - against - 22-CV-4475 (PKC) (MMH)

NYPD; and T. PRESCOD, #4974,

Defendants. -------------------------------------------------------x PAMELA K. CHEN, United States District Judge: By Memorandum and Order dated March 9, 2023, the Court granted Plaintiff leave to amend his Complaint.1 (Dkt. 11.) Plaintiff filed an Amended Complaint on April 6, 2023. (Dkt. 12.) For the reasons stated below, Plaintiff’s claim against the New York City Police Department (“NYPD”) is dismissed for failure to state a claim upon which relief may be granted. However, Plaintiff’s malicious prosecution claim against Detective Troy Prescod (“Prescod”) will proceed. BACKGROUND Plaintiff’s Amended Complaint asserts claims of false arrest, false imprisonment, and malicious prosecution against the NYPD and Prescod. (Dkt. 12, at ECF2 5.) Plaintiff alleges that Defendant Prescod entered his home without a search warrant on May 31, 2018. (Id. at ECF 6.) Prescod allegedly searched Plaintiff’s home and took Plaintiff to the 111th Precinct. (Id.) At the Precinct, Plaintiff was questioned for eight hours and then “transferred to Queens County Court, where [he] was held for an extra day[.]” (Id. at ECF 7.) “[S]hortly after,” Plaintiff was transferred

1 The Complaint was originally filed on July 18, 2022, in the United States District Court for the Southern District of New York. (Dkt. 1.) 2 Citations to “ECF” refer to the pagination generated by the Court’s CM/ECF docketing system and not the document’s internal pagination. to Rikers Island and held for 17 days. (Id.) Plaintiff claims he was falsely charged with burglary in the third degree, grand larceny in the third and fourth degrees, and criminal mischief in the second and fourth degrees. (Id.) On February 27, 2020, the criminal charges were dismissed. (Id. at ECF 9.) Plaintiff seeks monetary damages.

STANDARD OF REVIEW It is axiomatic that pro se complaints are held to less stringent standards than pleadings drafted by attorneys and the Court is required to read a plaintiff’s pro se complaint liberally and interpret it as raising the strongest arguments it suggests. Erickson v. Pardus, 551 U.S. 89, 94 (2007); Hughes v. Rowe, 449 U.S. 5, 9–10 (1980); Sealed Plaintiff v. Sealed Defendant #1, 537 F.3d 185, 191–93 (2d Cir. 2008). At the pleadings stage of the proceeding, the Court must assume the truth of “all well-pleaded, nonconclusory factual allegations” in the complaint. Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111, 123 (2d Cir. 2010) (citing Ashcroft v. Iqbal, 556 U.S. 662 (2009)). However, under 28 U.S.C. § 1915(e)(2)(B), a district court must dismiss an in forma pauperis action if the complaint “(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.” To avoid dismissal, a 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 on its face “when the plaintiff pleads factual content that allows the court to draw reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft, 556 U.S. at 678. DISCUSSION The Court construes the allegations of false arrest, false imprisonment, and malicious prosecution raised in Plaintiff’s Amended Complaint liberally to assert claims arising under 42 U.S.C. § 1983. “Section 1983 provides a cause of action against any person who deprives an individual of federally guaranteed rights ‘under color’ of state law.” Filarsky v. Delia, 566 U.S. 377, 383 (2012) (quoting 42 U.S.C. § 1983). Accordingly, to state a claim pursuant to Section 1983, a plaintiff must allege that the challenged conduct was “committed by a person acting under color of state law,” and that the conduct “deprived [the plaintiff] of rights, privileges, or immunities secured by the Constitution or laws of the United States.” Cornejo v. Bell, 592 F.3d 121, 127 (2d

Cir. 2010) (quoting Pitchell v. Callan, 13 F.3d 545, 547 (2d Cir. 1994)). A plaintiff seeking to recover damages under Section 1983 “must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.” Ashcroft, 556 U.S. at 678. I. Plaintiff’s Claims Against the NYPD The New York City Charter provides that “[a]ll 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. City Charter Ch. 17, § 396. The NYPD is an organizational subdivision of the City of New York and as such is not a suable entity. See, e.g., Jenkins v. City of New York, 478 F.3d 76, 93 n.19 (2d Cir. 2007) (“[The plaintiff] sued the City of New York and the NYPD separately. The district court correctly noted that the

NYPD is a non-suable agency of the City.”); Antonetti v. City of New York, No. 20-CV-5109 (BMC) (JRC), 2022 WL 1105172, at *2 (E.D.N.Y. Apr. 13, 2022) (dismissing claims against NYPD 103rd Precinct pursuant to Section 396). Therefore, all of Plaintiffs’ claims against the NYPD are dismissed. See 28 U.S.C. § 1915(e)(2)(B). II. Plaintiff’s Claims Against Defendant Prescod Section 1983 does not set forth a specific statute of limitations. See Owens v. Okure, 488 U.S. 235, 239 (1989) (noting “Congress’s failure to provide a specific statute of limitations to govern § 1983 actions”). Thus, “courts apply the statute of limitations for personal injury actions under state law.” Hogan v. Fischer, 738 F.3d 509, 517 (2d Cir. 2013) (citing Owens, 488 U.S. at 249–51). “Section 1983 actions filed in New York are . . . subject to a three-year statute of limitations.” Id.; Perez v. Cnty. of Nassau, 294 F. Supp. 2d 386, 389 (E.D.N.Y. 2003). As to when the limitations period begins to run, that is “a question of federal law, conforming in general to common-law tort principles.” McDonough v. Smith, 139 S. Ct. 2149, 2155 (2019) (citation and

quotation marks omitted). “For claims of malicious prosecution under Section 1983, the applicable limitations period does not accrue until there is a favorable termination of the plaintiff’s criminal proceedings.” Izeh v. City of New York, No. 23-CV-0194, 2023 WL 2088180 (LTS), at *2 (S.D.N.Y. Feb. 16, 2023) (citing Heck v.

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Related

Hughes v. Rowe
449 U.S. 5 (Supreme Court, 1980)
Owens v. Okure
488 U.S. 235 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kiobel v. Royal Dutch Petroleum Co.
621 F.3d 111 (Second Circuit, 2010)
Filarsky v. Delia
132 S. Ct. 1657 (Supreme Court, 2012)
Cornejo v. Bell
592 F.3d 121 (Second Circuit, 2010)
Sealed v. Sealed 1
537 F.3d 185 (Second Circuit, 2008)
Perez v. County of Nassau
294 F. Supp. 2d 386 (E.D. New York, 2003)
Hogan v. Fischer
738 F.3d 509 (Second Circuit, 2013)
McDonough v. Smith
588 U.S. 109 (Supreme Court, 2019)
Jenkins v. City of New York
478 F.3d 76 (Second Circuit, 2007)