Livingston v. United States

CourtDistrict Court, E.D. New York
DecidedSeptember 19, 2025
Docket1:24-cv-04489
StatusUnknown

This text of Livingston v. United States (Livingston v. United States) 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
Livingston v. United States, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------------------------------------- X NIGEL LIVINGSTON, : : Plaintiff, : MEMORANDUM DECISION AND : ORDER - against - : : 24-cv-4489 (BMC) UNITED STATES OF AMERICA, et al., : : Defendants. : ---------------------------------------------------------- X

COGAN, District Judge.

Plaintiff Nigel Livingston brings the instant case against the United States and Correction Officers Miguel Mateo and Jane Doe of the Federal Bureau of Prisons (“BOP”) for injuries he sustained while he was a pretrial detainee at the Brooklyn Metropolitan Detention Center. Plaintiff asserts two causes of action: (1) against the United States under the Federal Tort Claims Act (“FTCA”) for the officers’ negligence in failing to protect or otherwise prevent plaintiff from being attacked by inmates and for the officers’ deliberate indifference in denying and delaying medical care to plaintiff after the attack; and (2) against Officers Mateo and Doe under Bivens for violating plaintiff’s Fifth Amendment rights when they deliberately denied and delayed medical care to plaintiff despite his serious medical need. The Court previously denied defendants’ motion to dismiss the FTCA claim against the United States. Before the Court is defendants’ motion to dismiss the Bivens claim against Officer Mateo pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. For the reasons set forth below, the Court grants defendants’ motion to dismiss the Bivens claim. SUMMARY OF COMPLAINT Plaintiff became a pretrial detainee under the custody of the BOP in August 2021 while his criminal charges in the Southern District of New York were pending. Plaintiff was housed at the Brooklyn Metropolitan Correction Center.

On June 26, 2022 at approximately 8:30 p.m., plaintiff left his cell on the top tier to watch the BET Awards on the television downstairs. Upon leaving his cell, plaintiff noticed that Officers Mateo and Doe “were inside the office/bubble hanging out and talking with other inmates” – in plaintiff’s view, “not doing their jobs.” Two inmates then attacked plaintiff with sharp instruments outside of plaintiff’s cell. Plaintiff was in excruciating pain and realized that he had been stabbed in his neck and right hand. Plaintiff used towels to try to stop the bleeding and ran to Officers Mateo and Doe for help. He told the officers that he had been stabbed and was in pain. In response, the officers told plaintiff to return to his cell and wait for help to arrive. Plaintiff waited in his cell for 18 hours, screaming in pain and calling for help, but help never arrived.

At 2:00 p.m. the next day, plaintiff met with his attorney for a scheduled meeting. Plaintiff’s attorney noticed plaintiff’s injuries and alerted officers, who finally brought plaintiff to a hospital off-site. There, hospital personnel advised plaintiff that his wounds were deep and that he should have arrived sooner for proper treatment.1 Plaintiff received 18 stitches for the wound in his neck and 7 stitches for the wound in his right hand. He also received pain medication, antibiotics, and x-rays, and remained at the hospital overnight. Plaintiff continued taking antibiotics for several days thereafter.

1 Plaintiff does not allege, and hospital personnel presumably did not explain, how “proper treatment” would have differed from the treatment plaintiff ultimately received. 2 When plaintiff returned to the detention center, he was immediately placed in the “box” and segregated from the general population. He remained in the box for a month. While in the box, the BOP did not tell plaintiff’s family about the attack or about his placement in the box and denied plaintiff access to his attorney despite two scheduled visits.

Plaintiff felt pain for at least two months after the attack. He sustained “permanent disfiguring scars” on his neck and right hand and currently “suffers from permanent limitation in the use of his right hand,” including difficulty grasping and writing. Plaintiff also suffers from PTSD, fearing another attack and that “no help will come if he is attacked by another.” Based on the above allegations, plaintiff brings FTCA claims against the United States for the officers’ negligence which allowed the attack to occur and their subsequent deliberate indifference to plaintiff’s medical needs. Plaintiff also brings Bivens claims against Officers Mateo and Doe for violating plaintiff’s Fifth Amendment rights when they deliberately denied and delayed medical care to plaintiff despite his serious medical need. STANDARD OF REVIEW

To survive a motion to dismiss under Rule 12(b)(6), 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), and to “allow[ ] 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). When deciding a motion to dismiss, the Court must “constru[e] the complaint liberally, accept[ ] all factual allegations in the complaint as true, and draw[ ] all reasonable inferences in the plaintiff’s favor.” Elias v. Rolling Stone LLC, 872 F.3d 97, 104 (2d Cir. 2017) (quoting Chase Grp. All. LLC v. City of New York Dep’t of Fin., 620 F.3d 146, 150 (2d Cir. 2010)).

3 DISCUSSION In Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971), the Supreme Court recognized an implied private right of action against a federal agent who violated the Fourth Amendment in arresting the plaintiff and searching his home.

Within a decade, the Supreme Court permitted Bivens remedies in two additional contexts: a Fifth Amendment employment discrimination claim against a congressman, Davis v. Passman, 442 U.S. 228 (1979), and an Eighth Amendment claim brought by a deceased prisoner’s estate against prison officials for deliberate indifference to the prisoner’s serious medical needs, Carlson v. Green, 446 U.S. 14 (1980). Since deciding Carlson, the Supreme Court has declined every opportunity to extend Bivens to cover other constitutional violations, including in June of this year. See Goldey v. Fields, 606 U.S. 942, 942 (2025). As the Supreme Court has repeatedly made clear, “in all but the most unusual circumstances, prescribing a cause of action is a job for Congress, not the courts.” Id. at 942-43 (quoting Egbert v. Boule, 596 U.S. 482, 486 (2022)). To that end,

“recognizing a cause of action under Bivens is a disfavored judicial activity.” Id. at 944 (quotation marks omitted) (quoting Egbert, 596 U.S. at 491). In fact, the consistent rejection of any new claims under Bivens yields a reasonable conclusion that but for stare decisis, the Court would probably overrule Bivens. Instead, it has limited its scope as much as possible. This Court must apply the Supreme Court’s two-step test to determine whether plaintiff’s Bivens claim may proceed.

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Related

Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Green v. Carlson
581 F.2d 669 (Seventh Circuit, 1978)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)
Hernández v. Mesa
589 U.S. 93 (Supreme Court, 2020)
Egbert v. Boule
596 U.S. 482 (Supreme Court, 2022)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)
Elias v. Rolling Stone LLC
872 F.3d 97 (Second Circuit, 2017)
Edwards v. Gizzi
107 F.4th 81 (Second Circuit, 2024)
Goldey v. Fields
606 U.S. 942 (Supreme Court, 2025)

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Bluebook (online)
Livingston v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/livingston-v-united-states-nyed-2025.