McFadden v. Bradley

CourtDistrict Court, W.D. New York
DecidedMay 21, 2024
Docket1:22-cv-00074
StatusUnknown

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

Bluebook
McFadden v. Bradley, (W.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SS Pies Oy VAT WESTERN DISTRICT OF NEW YORK MAY 21 2024 Lap ew ly, Fe L +H ce ROBERT MCFADDEN, ESTERN DISTRICT OF Plaintiff, v. 22-CV-74 (JLS) JOHN T. BRADLEY, ESQ, TIMOTHY P. DONAHER, ESQ, and OFFICE OF THE PUBLIC DEFENDER, Defendants.

DECISION AND ORDER Pro se Plaintiff Robert McFadden is a prisoner confined at the Mid-State Correctional Facility. See Dkt. 1. He filed this action under 42 U.S.C. section 1983 alleging that Defendants violated his constitutional rights by failing to file a state court motion seeking a reduction in his sentence under New York State’s newly enacted Domestic Violence Survivors Justice Act, N.Y. Penal Law section 60.12.! McFadden claims he was entitled to a sentence reduction under this legislation because there was a “temporal nexus between [his] abuse and [the] offense” and that Defendants’ failure to file the requisite motion will result in a lengthier period

1 This statute authorizes “a court to impose reduced alternative, less severe, sentences in certain cases involving defendants who are victims of domestic violence.” People v. Burns, 207 A.D.3d 646, 648 (2d Dep’t 2022); see generally Donnino, McKinney’s Practice Commentary, N.Y. Penal Law, § 60.12 (2019).

of incarceration. Dkt. 1, at 7 J 9. McFadden also seeks permission to proceed in forma pauperis and has filed the requisite authorization. Dkt. 5. For the reasons below, McFadden’s motion to reopen this case and proceed in forma pauperis is granted and his claims are dismissed under 28 U.S.C. sections 1915(e)(2)(B)(@i) and 1915A—unless he files an amended complaint as directed below. DISCUSSION Because McFadden has met the statutory requirements of 28 U.S.C. section 1915(a) and filed the required authorization, Dkts. 2, 5, he is granted permission to proceed in forma pauperis. Therefore, under 28 U.S.C. sections 1915 and 1915A, this Court must screen his Complaint. Section 1915 “provide[s] an efficient means by which a court can screen for and dismiss legally insufficient claims.” Abbas v. Dixon, 480 F.3d 636, 639 (2d Cir. 2007) (citing Shakur v. Selsky, 391 F.3d 106, 112 (2d Cir. 2004)). The court shall dismiss a complaint in a civil action in which a prisoner seeks redress from a governmental entity, or an officer or employee of a governmental entity, if the court determines that the action (1) fails to state a claim upon which relief may be granted or (2) seeks monetary relief against a defendant who is immune from such relief. See 28 U.S.C. § 1915A(b)(1)-(2). Generally, the court will afford a pro se plaintiff an opportunity to amend or to be heard prior to dismissal “unless the court can rule out any possibility, however unlikely it might be, that an amended complaint would succeed in stating a claim.” Abbas, 480 F.3d at 639 (internal

quotation marks omitted). But leave to amend pleadings may be denied when any amendment would be futile. See Cuoco v. Moritsugu, 222 F.3d 99, 112 (2d Cir. 2000). I. THE COMPLAINT When evaluating a complaint, the court must accept all factual allegations as true and must draw all inferences in the plaintiffs favor. See Larkin v. Savage, 318 F.3d 138, 139 (2d Cir. 2003) (per curiam); King v. Simpson, 189 F.3d 284, 287 (2d Cir. 1999). “Specific facts are not necessary,” and the plaintiff “need only ‘give the defendant fair notice of what the .. . claim is and the grounds upon which it rests.” Erickson v. Pardus, 551 U.S. 89, 93 (2007) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)); see also Boykin v. Keycorp, 521 F.3d 202, 216 (2d Cir. 2008) (“[E]ven after Twombly, dismissal of a pro se claim as insufficiently pleaded is appropriate only in the most unsustainable of cases.”). Although “a court is obliged to construe [pro se] pleadings liberally, particularly when they allege civil rights violations,” McEachin v. McGuinnis, 357 F.3d 197, 200 (2d Cir. 2004), even pleadings submitted pro se must meet the notice requirements of Rule 8 of the Federal Rules of Civil Procedure, Wynder v. McMahon, 360 F.8d 78, 79 n.11 (2d Cir. 2004). McFadden has sued the Office of the Monroe County Public Defender, and two attorneys employed (or formerly employed) by the Monroe County Public Defenders’ Office, Timothy Donaher and John Bradley. A liberal reading of the Complaint alleges the following. In December 2014, McFadden was sentenced to an indeterminate sentence of imprisonment of seven-

and-one-half years to fifteen years, based on a Monroe County conviction of Manslaughter in the Second Degree. Dkt. 1, at 6 | 8. In or around August 2019, New York enacted new legislation, the Domestic Violence Survivors Act (the “Act”). N.Y. Penal L. § 60.12. This legislation permitted defendants to seek a reduction in their prison sentence by filing a motion under N.Y. Criminal Procedure Law (“CPL”), section 440.47, if there was a “temporal nexus between [the] abuse and offense.” Dkt. 1, at 799. A defendant eligible for relief under the Act is entitled to free legal representation. Id. at 7 J 10. Between December 2019 and February 2020, McFadden began writing to Defendant Donaher requesting representation to file a motion to reduce his sentence under CPL section 440.47. Donaher responded by forwarding a questionnaire to McFadden regarding the alleged nexus between McFadden’s domestic violence abuse and the offense for which he was convicted. Donaher also forwarded a request for documentation related to McFadden’s arrest, prosecution, and mental health treatment. Dkt. 1, at 7~8 | 12. McFadden responded to Donaher and maintained contact with Donaher between February and June 2020. Id. at 8 | 13. Because Donaher did not initially receive McFadden’s responsive documents, McFadden re-sent the documents on June 28, 2020. Id. at 8 JJ 14-15. In August 2020, Donaher notified McFadden that his matter had been assigned to Defendant Bradley. Between August 2020 and October 2021, Bradley failed to communicate with McFadden regarding the motion to reduce McFadden’s sentence. McFadden alleges that it should have been clear to Bradley and Donaher

that the motion was premised on the abuse suffered at the hands of his wife and not any childhood abuse, and that the nexus between the abuse and McFadden’s offense was established through the police records. fd. at 9-10 {| 17-19. He also alleges that Defendants failed to investigate the evidence and take the necessary steps to understand the nature of his domestic violence history for purposes of filing a motion. Jd. at 10 f 20.

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McFadden v. Bradley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcfadden-v-bradley-nywd-2024.