Jerome Mack v. New York State, et al.

CourtDistrict Court, N.D. New York
DecidedFebruary 17, 2026
Docket9:25-cv-01425
StatusUnknown

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

Bluebook
Jerome Mack v. New York State, et al., (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

JEROME MACK,

Plaintiff, 9:25-CV-1425 (BKS/DJS) v.

NEW YORK STATE, et al.,

Defendants.

APPEARANCES: OF COUNSEL:

JEROME MACK Plaintiff, pro se 15-A-2518 Shawangunk Correctional Facility P.O. Box 700 Wallkill, NY 12589

BRENDA K. SANNES Chief United States District Judge DECISION AND ORDER I. INTRODUCTION In October 2025, pro se plaintiff Jerome Mack ("plaintiff") commenced this action by submitting a complaint pursuant to 42 U.S.C. § 1983 ("Section 1983"). Dkt. No. 1 ("Compl."). Plaintiff also filed an application to proceed in forma pauperis ("IFP"). Dkt. No. 8. By Decision and Order filed on December 4, 2025 (the "December 2025 Order"), this Court granted plaintiff's IFP application and reviewed the sufficiency of the complaint in accordance with 28 U.S.C. §§ 1915(e) and 1915A. Dkt. No. 10. The Court found that the complaint failed to state a claim and dismissed all claims. See id. In light of plaintiff's pro se status, he was afforded an opportunity to file an amended complaint. See id. On October 20, 2025, plaintiff filed amended complaint (Dkt. No. 12) ("Am. Compl."). II. SUFFICIENCY OF AMENDED COMPLAINT

A. Legal Standard The legal standard governing the dismissal of a pleading for failure to state a claim pursuant to 28 U.S.C. § 1915(e) and § 1915A was discussed at length in the December 2025 Order and will not be restated in this Decision and Order. See Dkt. No. 10 at 2-4. B. Summary of Amended Complaint1 With the amended complaint, plaintiff identifies the following new defendants: Correctional Officer K. Premo ("Premo"), Superintendent Daniel Senkowski ("Senkowski"), and Commissioners Hearing Officer ("CHO") Philli ("Philli").2 See generally Am. Compl. The amended complaint also includes claims against the previously named defendants, New York State, Commissioner Glenn S. Goord ("Goord"), City of Plattsburgh, and Correctional Officer

Gerald Corrigan ("Corrigan"). See id. On May 5, 2001, Corrigan escorted plaintiff to an area to be frisked. Am. Compl. at 4. When plaintiff arrived in the frisk booth, Corrigan noticed two balloons, containing an

1 The amended complaint includes exhibits. Am. Compl. at 20-43. To the extent that the exhibits are relevant to the incidents described in the amended complaint, the Court will consider the amended complaint as well as any documents attached as exhibits. See Cortec Indus., Inc. v. Sum Holding L.P., 949 F.2d 42, 47 (2d Cir. 1991) (the complaint is deemed to include any written instrument attached to it as an exhibit or any statements or documents incorporated in it by reference).

2 The Clerk of the Court is directed to amend the Docket Report to include these defendants.

2 unknown substance, on the ledge of the booth. Id. Corrigan ordered plaintiff to retrieve the balloons before commencing the search, and plaintiff complied. Id. On May 5, 2001, Premo and Corrigan issued a misbehavior report charging plaintiff with possession of 16 grams of marijuana. Am. Compl. at 2; 21, 23. Corrigan told plaintiff, "I

know you didn't do anything wrong but they want your [expletive] bad[.]" Id. at 2. On May 9, 2001, Philli presided over a hearing related to the misbehavior report. Am. Compl. at 3, 25. Senkowski was present and told plaintiff that if he did not plead guilty, that Senkowski would "enact criminal charges against him pursuant to NYS Directive 6910." Id. at 3. Philli reiterated Senkowski's threat. Id. Plaintiff maintained his innocence and requested video evidence. Id. At the conclusion of the hearing, plaintiff was found guilty of all charges. Id. at 3, 29. Plaintiff was sentenced to 180 days in the Special Housing Unit ("SHU") with a loss of privileges and good time credits. Am. Compl. at 5, 29. On May 14, 2001, plaintiff appealed the determination to Senkowski. Am. Compl. at 3, 32. Senkowski "rejected" the appeal. Id. at 3.

Plaintiff was indicted and charged with violations of the Penal Law. Am. Compl. at 4. The indictment indicated that "the amount of drugs recovered was 9.4 grams." Id. at 3, 40- 41. Plaintiff accepted a plea offer from the prosecutor. Id. at 5. As a result of his conviction, plaintiff served two years in prison. Id. In July 2023, plaintiff's conviction was vacated. Am. Compl. at 5, 35-36.

3 Construing the amended complaint liberally3, plaintiff asserts: (1) due process claims; (2) malicious prosecution and wrongful confinement claims; (3) failure to supervise claims; (4) Eighth Amendment claims; (5) municipal liability claims; and (6) state constitutional claims. See generally Am. Compl. Plaintiff seeks monetary damages. See id. at 19.

C. Analysis 1. Eleventh Amendment The law related to the Eleventh Amendment was discussed in the December 2025 Order and will not be restated herein. Dkt. No. 10 at 7. In the December 2025 Order, the Court dismissed plaintiff's §1983 claims against the State of New York as barred by the Eleventh Amendment. See id. To the extent that plaintiff attempts to reassert these claims, those claims are dismissed. 2. Fourteenth Amendment – Due Process The law related to Fourteenth Amendment due process claims was discussed in the December 2025 Order. Dkt. No. 10 at 8.

a. Claims Related to Criminal Indictment In the December 2025 Order, the Court dismissed plaintiff's due process claim related to being "overcharged for a crime that he did not commit" due to lack of personal involvement in plaintiff's criminal prosecution. See Dkt. No. 10 at 8.

3 The Court is mindful of the Second Circuit's instruction that a pleading by a pro se litigant must be construed liberally and interpreted to raise the strongest arguments that it suggests. See, e.g., Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008) ("On occasions too numerous to count, we have reminded district courts" that a pro se plaintiff's pleadings must be construed liberally); Phillips v. Girdich, 408 F.3d 124, 130 (2d Cir. 2005) ("We leave it for the district court to determine what other claims, if any, [plaintiff] has raised. In so doing, the court's imagination should be limited only by [plaintiff's] factual allegations, not by the legal claims set out in his pleadings."); Burgos v. Hopkins, 14 F.3d 787, 790 (2d Cir. 1994) ("[W]e read [a pro se litigant's] supporting papers liberally, and will interpret them to raise the strongest arguments that they suggest."). 4 The Court has reviewed the allegations in the amended complaint and finds that plaintiff's allegations do not remedy the deficiencies of this claim, as addressed in the December 2025 Order. Thus, for the reasons set forth in the prior Order, plaintiff's due process claims related to his criminal indictment are dismissed.

b. Claims Related to Disciplinary Hearing

With the amended complaint, plaintiff identified Philli as a Hearing Officer and provided new facts related to a disciplinary hearing and the outcome. See generally Am. Compl. Plaintiff claims that Philli violated his Fourteenth Amendment rights when he refused to allow "the plaintiff witness during his hearing process." Id. at 12.

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Jerome Mack v. New York State, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jerome-mack-v-new-york-state-et-al-nynd-2026.