Brown v. Suffolk County Police Department 7th Precient

CourtDistrict Court, E.D. New York
DecidedFebruary 6, 2025
Docket2:25-cv-00094
StatusUnknown

This text of Brown v. Suffolk County Police Department 7th Precient (Brown v. Suffolk County Police Department 7th Precient) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Suffolk County Police Department 7th Precient, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------------------------------------x DAVID BROWN,

Plaintiff, MEMORANDUM -against- AND ORDER 25-CV-0094-SJB-ST SUFFOLK COUNTY POLICE DEPARTMENT 7th PRECINCT, et al.,

Defendants. --------------------------------------------------------------x BULSARA, United States District Judge: Pro se Plaintiff David Brown (“Brown” or “Plaintiff”) currently incarcerated at the Suffolk County Correctional Facility (“SCCF”) in Riverhead, New York filed this pro se action alleging violations of 42 U.S.C. § 1983 (“Section 1983”) by the Suffolk County Police Department 7th Precinct, (“SCPD”), the Suffolk County District Attorney’s Office (“SCDA”), and three unidentified individuals police officers working from the SCPD (“Individual Defendants”). (Compl. dated Jan. 6, 2025 (“Compl.”), Dkt. No. 1. at 2-3). Brown also filed a motion to proceed in forma pauperis (“IFP”). (IFP Mot. dated Jan. 6, 2025 (“IFP Mot.”), Dkt. No. 2). Brown’s request to proceed IFP is granted. But for the reasons discussed below, Brown’s claims against the SCPD and the SCDA are dismissed with prejudice. Brown’s claims against the Individual Defendants will proceed. STANDARDS A complaint must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A complaint must contain more than “naked assertion[s] devoid of further factual enhancement.” Id. (quotations omitted). In other words, a plausible claim contains “factual content that allows the court to draw

the reasonable inference that the defendant is liable for the misconduct alleged.” Id.; Fed. R. Civ. P. 8(a)(2). “Factual allegations must be enough to raise a right to relief above the speculative level, on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Twombly, 550 U.S. at 555 (internal citations omitted). The determination of whether a party has alleged a plausible claim is “a context-specific task that requires the reviewing court to draw on its judicial experience and common

sense.” Iqbal, 556 U.S. at 679; see also Escamilla v. Young Shing Trading Co., No. 17-CV- 652, 2018 WL 1521858, at *2 (E.D.N.Y. Jan. 8, 2018), report and recommendation adopted, 2018 WL 1033249, at *3 (Feb. 23, 2018). A pro se plaintiff’s pleadings are held “to less stringent standards than formal pleadings drafted by lawyers[.]” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)); see also Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009) (noting that “[e]ven after Twombly,” courts “remain obligated to construe

a pro se complaint liberally”). “Where, as here, the complaint was filed pro se, it must be construed liberally with ‘special solicitude’ and interpreted to raise the strongest claims that it suggests.” Hogan v. Fischer, 738 F.3d 509, 515 (2d Cir. 2013) (quoting Hill v. Curcione, 657 F.3d 116, 122 (2d Cir. 2011)); Bertin v. United States, 478 F.3d 489, 491 (2d Cir. 2007) (“We liberally construe pleadings and briefs submitted by pro se litigants . . . ‘to raise the strongest arguments they suggest’”) (quoting Burgos v. Hopkins, 14 F.3d 787, 790 (2d Cir.1994). “This is particularly so when the pro se plaintiff alleges that [his] civil rights have been violated.” Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008).

Nonetheless, even pro se complaints must contain sufficient factual allegations to allege a plausible claim. Hogan, 738 F.3d at 515; Chavis v. Chappius, 618 F.3d 162, 170 (2d Cir. 2010). Under the IFP statute, 28 U.S.C. § 1915(e)(2)(B), a district court must dismiss an IFP action where it is satisfied that 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.” “An action is frivolous when either: (1) the

factual contentions are clearly baseless, such as when allegations are the product of delusion or fantasy; or (2) the claim is based on an indisputably meritless legal theory.” Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998) (citations and quotations omitted); see 28 U.S.C. § 1915A(b).1 DISCUSSION Brown commenced this action on January 6, 2025 (Compl.), and filed an IFP motion with his Complaint. (IFP Mot.). Brown names the SCPD, the SCDA, and three

Individual Defendants and alleges false arrest pursuant to Section 1983. Brown alleges that he was arrested on June 18, 2024 and charged with criminal possession of a controlled substance—cocaine—that was later determined to be caffeine. (Compl. at 4.

1 Like the IFP statute, the Prison Litigation Reform Act requires a district court to screen a complaint brought by a prisoner against a governmental entity or its agents and dismiss the complaint, or any portion of it, if the complaint is “frivolous, malicious, or fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(1). ¶ II.) Although he was detained at the SCCF for seven months, Brown alleges that these charges were “eventually dismissed.” (Id.) Brown seeks damages for pain, suffering, defamation, mental anguish and other injuries. (Id. at 4-5, ¶¶ II.A.-III.).

Brown brought this action pursuant to Section 1983. (Compl. at 1). Section 1983 provides that: Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State ... subjects, or causes to be subjected, any citizen of the United States ... to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured[.]

42 U.S.C. § 1983. To state a claim for relief under Section 1983, a plaintiff must allege that defendants violated the plaintiff’s constitutional or federal rights while acting under color of state law. 42 U.S.C. § 1983; see also Washington v. County of Rockland, 373 F.3d 310, 315 (2d Cir. 2004).

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
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)
Chavis v. Chappius
618 F.3d 162 (Second Circuit, 2010)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Washington v. County Of Rockland
373 F.3d 310 (Second Circuit, 2004)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Sealed v. Sealed 1
537 F.3d 185 (Second Circuit, 2008)
Hogan v. Fischer
738 F.3d 509 (Second Circuit, 2013)
Henry v. Nassau County
6 F.4th 324 (Second Circuit, 2021)

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Bluebook (online)
Brown v. Suffolk County Police Department 7th Precient, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-suffolk-county-police-department-7th-precient-nyed-2025.