McKinney v. Dougherty

CourtDistrict Court, D. Connecticut
DecidedFebruary 28, 2025
Docket3:24-cv-01024
StatusUnknown

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

Bluebook
McKinney v. Dougherty, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WILLIAM MCKINNEY, : Plaintiff, : : v. : No. 3:24-cv-1024 (VAB) : DANIEL DOUGHERTY, et al., : Defendants. :

RULING AND ORDERS ON PENDING MOTIONS

Before the Court for further review are plaintiff William McKinney’s amended complaints, see ECF Nos. 14, 42, 43, 58, and fourteen pending pro se motions. ECF Nos. 9, 10, 15, 16, 27, 33, 49, 50, 52, 55, 56, 57, 61, 62. For reasons that follow, Mr. McKinney’s Motion for Leave to File Amended Complaint, ECF No. 55, is GRANTED. All other pending motions are DENIED. Mr. McKinney may pursue his Eighth Amendment deliberate indifference claim for damages against Warden Dougherty, Lieutenant Pearson, and Lieutenant Peau in their individual capacities. All other claims, and all other Defendants are dismissed from this case. I. BACKGROUND Mr. McKinney filed a pro se Complaint under 42 U.S.C. § 1983, while housed at Corrigan-Radgowski Correctional Center (“Corrigan”). ECF No. 1 at 2. He sued two Corrigan officials—Warden Dougherty and Lieutenant Pearson—for violating his constitutional rights. Id. at 2–3. U.S. District Judge Jeffrey Alker Meyer reviewed Mr. McKinney’s original Complaint. See ECF No. 13. Judge Meyer permitted Mr. McKinney to pursue his Eighth Amendment deliberate indifference claim for damages against Warden Dougherty and Lieutenant Pearson. Id. at 7. Judge Meyer dismissed Mr. McKinney’s First Amendment retaliation claim without prejudice. Id. But Judge Meyer permitted Mr. McKinney to file an Amended Complaint within thirty days

of the initial review order, if Mr. McKinney had “good faith grounds to allege additional facts that overcome the grounds stated in this ruling for dismissing his claims.” Id. In addition to filing twelve motions, Mr. McKinney has since filed four Amended Complaints. See ECF Nos. 14, 42, 43, 58. Mr. McKinney filed his first Amended Complaint within thirty days of the initial review order. See ECF No. 14. Mr. McKinney then filed a motion for extension of time to file another Amended Complaint. ECF No. 34. Judge Meyer granted that motion, giving Mr. McKinney until August 23, 2024, to file a Second Amended Complaint. ECF No. 41. Mr. McKinney filed a Second and Third Amended Complaint on August 12, 2024, and August 20, 2024, respectively. ECF Nos. 42, 43. But before Judge Meyer could conduct his

initial review of these amended pleadings, Mr. McKinney filed two motions for leave to amend his Complaint, ECF Nos. 50, 55, and a Fourth Amended Complaint. ECF No. 58. II. DISCUSSION After transfer of Mr. McKinney’s case to this Court on January 17, 2025, ECF No. 54, there are now fourteen pending motions, awaiting initial review of Mr. McKinney’s Fourth Amended Complaint. A. Motion for Leave to Amend Complaint (ECF No. 55) Under Rule 15(a)(1), “[a] party may amend its pleading once as a matter of course no

2 later than: (A) 21 days after serving it, or (B) if the pleading is one to which a responsive pleading is required, 21 days after service of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), whichever is earlier.” Fed. R. Civ. P. 15(a)(1). In Mr. McKinney’s most recent Motion for Leave to Amend Complaint, ECF No. 55, he moved to

amend his Complaint under Rule 15(a) of the Rules of Civil Procedure. Id. at 1. The original Complaint was served on Defendants on July 2, 2024. ECF No. 32. Judge Meyer granted Defendants an extension of time to file a responsive pleading, see ECF No. 46, but Defendants have yet to do so. Thus, the “earlier” of the conditions described in Rule 15(a)(1) is twenty-one days after service of the Complaint. Mr. McKinney’s motion for leave to file amended complaint, filed on January 23, 2025, ECF No. 55, is beyond the time limit for amending his Complaint “as a matter of course” under Rule 15(a)(1). If a party may not amend a pleading as a matter of course under Rule 15(a)(1), that “party may amend its pleading only with the opposing party’s written consent or the court’s leave” under Rule 15(a)(2). Mr. McKinney did not state in his motion that Defendants consented to him

amending his Complaint. See ECF No. 55. But he has sought leave of court to do so, and “[t]he court should freely give leave when justice so requires” under Rule 15(a)(2). The Court may deny leave to amend, however, for “undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of the amendment, etc.” Ruotolo v. City of New York, 514 F.3d 184, 191 (2d Cir. 2008) (quoting Foman v. Davis, 371 U.S. 178, 192 (1962) (internal quotation marks omitted)). But the non-moving party bears the burden of showing prejudice, bad faith, or futility of the

3 amendment. See Perez v. Escobar Constr., Inc., 342 F.R.D. 378, 380 (S.D.N.Y. 2022) (citation omitted). Because the non-moving party has not resisted Mr. McKinney’s Motion for Leave to File Amended Complaint on any of these grounds, the Court concludes that justice requires granting leave to amend.

Accordingly, Mr. McKinney’s Motion for Leave to File Amended Complaint, ECF No. 55, will be granted, his motion for leave to amend Complaint, ECF No. 50, will be denied as moot, and the Fourth Amended Complaint will be the operative pleading. See Int’l Controls Corp. v. Vesco, 556 F.2d 665, 668 (2d Cir. 1977) (noting that “an amended complaint ordinarily supersedes the original and renders it of no legal effect”). B. The Initial Review of Fourth Amendment Complaint Under 28 U.S.C. § 1915A(b), district courts must review prisoners’ civil complaints against governmental actors and sua sponte “dismiss . . . any portion of [a] complaint [that] is frivolous, malicious, or fails to state a claim upon which relief may be granted,” or that “seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b); see

also Liner v. Goord, 196 F.3d 132, 134 & n.1 (2d Cir. 1999) (explaining that, under the Prisoner Litigation Reform Act, sua sponte dismissal of frivolous prisoner complaints is mandatory); Tapia-Ortiz v. Winter, 185 F.3d 8, 11 (2d Cir. 1999) (“Section 1915A requires that a district court screen a civil complaint brought by a prisoner against a governmental entity or its agents and dismiss the complaint sua sponte if, inter alia, the complaint is ‘frivolous, malicious, or fails to state a claim upon which relief may be granted.’” (quoting 28 U.S.C. § 1915A)). Rule 8 of the Federal Rules of Civil Procedure requires that a plaintiff plead only “a short and plain statement of the claim showing that the pleader is entitled to relief,” see Fed. R. Civ. P.

4 8(a)(2), to provide the defendant “fair notice of what the . . .

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McKinney v. Dougherty, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinney-v-dougherty-ctd-2025.