Kendrick v. Brooklyn District Attorney's Office

CourtDistrict Court, E.D. New York
DecidedApril 29, 2025
Docket1:25-cv-01620
StatusUnknown

This text of Kendrick v. Brooklyn District Attorney's Office (Kendrick v. Brooklyn District Attorney's Office) 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
Kendrick v. Brooklyn District Attorney's Office, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK RANDY KENDRICK, Plaintiff, v. MEMORANDUM & ORDER 25-CV-1620 (HG) (JAM) BROOKLYN DISTRICT ATTORNEY’S OFFICE; ERIC GONZALEZ, District Attorney of Kings County; JOHN DOES, Assistant District Attorneys, Defendants. HECTOR GONZALEZ, United States District Judge: On March 20, 2025, Plaintiff Randy Kendrick, a pretrial detainee at a Rikers Island facility, brought this action pro se pursuant to 42 U.S.C. § 1983 (“Section 1983”) and names the Brooklyn District Attorney’s Office, Brooklyn District Attorney Eric Gonzalez (“DA Gonzalez”), and John Doe assistant district attorneys (the “ADAs”) as defendants. See ECF No. 1 (Compl.). The Court grants Plaintiff’s request to proceed in forma pauperis (“IFP”), pursuant to 28 U.S.C. § 1915. See ECF No. 2 (IFP Mot.). For the reasons discussed below, the action is dismissed. BACKGROUND Plaintiff brings this action in connection with his pending state criminal case in Kings County.1 Plaintiff’s asserted basis for jurisdiction involves violations of his federal 1 The Complaint does not contain information about the underlying criminal case. The Court takes judicial notice that, according to New York State records, the incident underlying Plaintiff’s arrest occurred on October 8, 2024, and Plaintiff was arrested on October 17, 2024. Plaintiff is charged with, inter alia, rape in the first degree and assault with a deadly weapon in the second degree. Plaintiff’s case is pending in New York Supreme Court, Kings County, and his next appearance is scheduled for June 18, 2025. See Case Information for IND-76580- 24/001, https://iapps.courts.state.ny.us/webcivil/ecourtsMain. constitutional rights pursuant to Section 1983. See ECF No. 1 at 8. Plaintiff alleges that he has been improperly detained for 180 days following his arrest on October 17, 2024. See id. at 4, 5, 8. He alleges that the Brooklyn District Attorney’s Office, DA Gonzalez, and the ADAs violated his constitutional rights by failing to properly serve him, to file a certificate of compliance, or to

provide required discovery materials under New York Criminal Procedure Law § 245.10. See id. at 5, 9. Plaintiff asserts that these failures violated his right to due process under the Fourteenth Amendment, his right to be free from unreasonable seizure under the Fourth Amendment, and his right to a speedy trial under the Sixth Amendment. Id. at 5, 9–11. He also alleges that the Brooklyn District Attorney’s Office, under the direction of DA Gonzalez, established and maintained certain enumerated “policies, practices, and customs” that caused the alleged constitutional violations. See id. at 12. Plaintiff seeks money damages. See id. at 6, 12. STANDARD OF REVIEW 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).2 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). Although all allegations contained in the complaint are assumed to be true, this tenet is “inapplicable to legal conclusions.” Id. A pro se complaint “must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007); see also Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009) (noting that even after Twombly, courts “remain obligated to construe a pro se complaint liberally”).

2 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted. A district court “shall review, before docketing, if feasible or, in any event, as soon as practicable after docketing, a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A. Upon review, a district court shall dismiss a prisoner’s complaint sua sponte if the complaint is

“(1) frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id.; Liner v. Goord, 196 F.3d 132, 134 (2d Cir. 1999) (under the Prison Litigation Reform Act, sua sponte dismissal of frivolous prisoner complaints is not only permitted but mandatory). Similarly, a district court shall review an IFP action and dismiss it where it finds 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.” 28 U.S.C. § 1915(e)(2)(B). A complaint will be dismissed as frivolous if it is based on an indisputably meritless legal theory or when the defendants are immune from suit. See Kelsey v. Clark, No. 22-22, 2023 WL 1980307, at *1 (2d Cir. Feb. 14, 2023).

DISCUSSION I. Plaintiff’s Claims Against the Brooklyn District Attorney’s Office Plaintiff’s claims against the Brooklyn District Attorney’s Office cannot proceed because a district attorney’s office is not a suable entity. See Barreto v. Cnty. of Suffolk, 455 F. App’x 74, 76 (2d Cir. 2012) (finding claims against a district attorney’s office meritless because a district attorney’s office is “not an entity capable of being sued”). Therefore, Plaintiff’s claims against the Brooklyn District Attorney’s Office must be dismissed. II. Plaintiff’s Claims Against DA Gonzalez and the ADAs Plaintiff’s claims against DA Gonzalez and the ADAs, in both their official and individual capacities, must also be dismissed because they are barred by immunity doctrines. See Montero v. Travis, 171 F.3d 757, 760 (2d Cir. 1999) (“A complaint will be dismissed as

‘frivolous’ when ‘it is clear that the defendants are immune from suit.’”). The Eleventh Amendment doctrine of sovereign immunity protects district attorneys and assistant district attorneys from lawsuits brought against them in their official capacities. See Amaker v. N.Y. State Dept. of Corr. Servs., 435 Fed. App’x. 52, 54 (2d Cir. 2011) (holding that a district attorney and an assistant district attorney “benefited from New York’s Eleventh Amendment immunity against suit” because they were sued in their official capacities). When a state official, like a district attorney or assistant district attorney, is sued for damages in her official capacity, “such a suit is deemed to be a suit against the state, and the official is entitled to invoke the Eleventh Amendment immunity belonging to the state.” Ying Jing Gan v. City of New York, 996 F.2d 522, 529 (2d Cir. 1993). Therefore, the claims Plaintiff brings against DA

Gonzalez and the ADAs, in their official capacities, are barred by the Eleventh Amendment doctrine of sovereign immunity.

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
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)
Van de Kamp v. Goldstein
555 U.S. 335 (Supreme Court, 2009)
Ying Jing Gan v. The City Of New York
996 F.2d 522 (Second Circuit, 1993)
Barreto v. County of Suffolk
455 F. App'x 74 (Second Circuit, 2012)
Grullon v. City of New Haven
720 F.3d 133 (Second Circuit, 2013)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Anilao v. Spota
27 F.4th 855 (Second Circuit, 2022)

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Bluebook (online)
Kendrick v. Brooklyn District Attorney's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kendrick-v-brooklyn-district-attorneys-office-nyed-2025.