Bailey v. City of New York

CourtDistrict Court, S.D. New York
DecidedApril 15, 2024
Docket1:23-cv-08187
StatusUnknown

This text of Bailey v. City of New York (Bailey v. City of New York) 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
Bailey v. City of New York, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CRAIG BAILEY, Plaintiff, -against- 23-CV-8187 (LTS) CITY OF NEW YORK; MAYOR ERIC ADAMS; NYC DEP’T OF CORR. ORDER TO AMEND COMMISSIONER; WARDEN, ERIC M. TAYLOR CENTER, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who currently is detained at the Eric M. Taylor Center (“EMTC”) on Rikers Island, brings this pro se action, alleging that Defendants violated his rights. The Court construes the complaint as asserting constitutional claims under 42 U.S.C. § 1983, as well as claims under state law. By order dated September 20, 2023, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees.1 For the reasons set forth below, the Court grants Plaintiff leave to file an amended complaint within 60 days of the date of this order. STANDARD OF REVIEW The Prison Litigation Reform Act requires that federal courts screen complaints brought by prisoners who seek relief against a governmental entity or an officer or employee of a governmental entity. See 28 U.S.C. § 1915A(a). The Court must dismiss a prisoner’s IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune

1 Prisoners are not exempt from paying the full filing fee even when they have been granted permission to proceed IFP. See 28 U.S.C. § 1915(b)(1). from such relief. 28 U.S.C. §§ 1915(e)(2)(B), 1915A(b); see Abbas v. Dixon, 480 F.3d 636, 639 (2d Cir. 2007). The Court must also dismiss a complaint if the court lacks subject matter jurisdiction. 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. BACKGROUND Plaintiff, who is a pretrial detainee, brings this action against the City of New York, Mayor Eric Adams, the Commissioner of the New York City Department of Correction (“DOC”), and the Warden of the Eric M. Taylor Center (“EMTC”). He asserts that Defendants

violated his rights by denying him recreation and access to a law library since August 5, 2023. Plaintiff seeks access to a law library, a daily hour of recreation, and money damages. The following information is taken from the complaint. On August 5, 2023, Plaintiff requested both library access and recreational services, but a John Doe correction officer stated “we dont run rec in this jail and law library comes when they want if they come at all.” (ECF 1, at 4.)2 When Plaintiff made his requests to the area supervisor, Captain Davis, Plaintiff received

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. the same response. The next day, Plaintiff filed a grievance, but he did not hear anything from the Inmate Grievance Resolution Committee (“IGRC”). He asked Supervisor Singh about IGRC, but was told that “they don’t have an I.G.R.C. staff here.” (Id.) Plaintiff’s inability to “properly prepare” for his upcoming court appearances “has cause

[his] mental state to become deplorable.” (Id. at 5.) He has also not been “able to maintain [his] physical health with[out] proper recreation.” (Id.) DISCUSSION A. Access to the Courts The Court liberally construes Plaintiff’s claim that he has been denied access to a law library at EMTC as arising under the First Amendment. Prisoners have “a constitutional right of access to the courts [that] gives rise to a number of derivative rights, including the right to access legal materials to prepare a case, and the right of indigent inmates to be provided with paper and pens to draft legal documents and stamps to mail them.” Collins v. Goord, 581 F. Supp. 2d 563, 573 (S.D.N.Y. 2008) (citing Bounds v. Smith, 430 U.S. 817, 824-28 (1977)). Protecting these rights “requires prison authorities to assist inmates in the preparation and filing of meaningful

legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.” Bourdon v. Loughren, 386 F.3d 88, 92–93 (2d Cir. 2004) (quoting Bounds, 420 U.S. at 821, 828). Assistance from prison authorities, however, is “only the means for ensuring a reasonably adequate opportunity to present claimed violations of fundamental constitutional rights to the courts.” Lewis v. Casey, 518 U.S. 343, 351 (1996) (internal quotation marks omitted). To state a claim for denial of access to the courts, a plaintiff must allege facts showing that the defendant’s conduct: (1) “was deliberate and malicious,” and (2) “resulted in actual injury to the plaintiff such as the dismissal of an otherwise meritorious legal claim.” Davis v. Goord, 320 F.3d 346, 351 (2d Cir. 2003) (internal quotation marks omitted); see also Christopher v. Harbury, 536 U.S. 403, 415 (2002). To demonstrate actual injury, a plaintiff must allege: (1) a valid underlying cause of action separate from the right-of-access claim; and (2) frustration or hindrance of the litigation caused by the defendant’s actions. See Harbury, 546

U.S. at 415. A mere “delay in being able to work on one’s legal action or communicate with the courts does not rise to the level of a constitutional violation.” Jermosen v. Coughlin, 877 F. Supp. 864, 871 (S.D.N.Y. 1995) (citing Jones v. Smith, 784 F.2d 149, 151- 52 (2d Cir. 1986)). Furthermore, when a prisoner with appointed counsel claims that prison officials hindered his efforts to defend himself or pursue other legal claims, “he must show that, on the facts of his case, the provision of counsel did not furnish him with the capability of bringing his challenges before the courts.” Bourdon, 386 F.3d at 98. Here, Plaintiff, who is a pretrial detainee with pending criminal proceedings, asserts that he was denied access to a law library to prepare for his upcoming court proceedings. He does not, however, allege any facts suggesting that he is pursuing a “nonfrivolous, ‘arguable’

underlying claim” that has been hindered as a result of the lack of law library. Harbury, 546 U.S. at 415.

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Bluebook (online)
Bailey v. City of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bailey-v-city-of-new-york-nysd-2024.