Rivers v. Squires

CourtDistrict Court, W.D. New York
DecidedMay 24, 2024
Docket1:23-cv-00154
StatusUnknown

This text of Rivers v. Squires (Rivers v. Squires) 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
Rivers v. Squires, (W.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JANE RIVERS,

Plaintiff, 23-CV-154-LJV v. DECISION & ORDER

SUSAN SQUIRES, et al.,

Defendants.

On February 17, 2023, the plaintiff—proceeding pseudonymously as “Jane Rivers”—commenced this action under 42 U.S.C. § 1983 and New York State law raising claims related to an alleged sexual assault she experienced while incarcerated at the Albion Correctional Facility (“Albion”). Docket Item 1. In addition to asserting claims against the correction officer who allegedly assaulted her,1 Rivers asserts two claims against Albion Superintendent Susan Squires: (1) an Eighth Amendment claim for deliberate indifference, id. at ¶¶ 160-67, and (2) a First Amendment claim for retaliation, id. at ¶¶ 168-74. On February 9, 2024, Squires moved to dismiss the retaliation claim. Docket Item 17. Rivers then responded, Docket Item 22, and Squires replied, Docket Item 25. For the reasons that follow, Squires’s motion to dismiss is denied.

1 Rivers asserts three claims against Correction Officer Jonathan DeJesus. Docket Item 1 at ¶¶ 147-59. BACKGROUND2

Albion is an “all-female prison” operated by the New York State Department of Corrections and Community Supervision (“DOCCS”). Docket Item 1 at ¶ 19. On or about August 22, 2022, Rivers and Officer DeJesus were working in the Albion infirmary. Id. at ¶¶ 27-28. Throughout the day, DeJesus harassed and sexually touched Rivers without her consent. Id. at ¶¶ 30-35. Eventually, DeJesus “instructed [Rivers] to follow him into the infirmary bathroom,” where he raped her. Id. at ¶¶ 37-47. Rivers “reported the rape late that evening or early the following morning” and “was taken to the hospital,” where “a rape kit was performed.” Id. at ¶¶ 49-52. After she reported the rape, Rivers “was placed in solitary confinement” and then

“transferred to Beford Hills Correctional Facility” (“Bedford”). Id. at ¶¶ 55-56. Squires “allowed or ordered” Rivers “to be held in isolation” and “to be moved to [Bedford].” Id. at ¶¶ 169-70. “As a result of being transferred to [Bedford], [Rivers] was unable to complete the class she was taking at Albion[,] . . . which would have allowed her to be released from custody in October 2022.” Id. at ¶ 57. Because “she was unable to complete the class, [Rivers] was not released until January 17, 2023.” Id. at ¶¶ 58-59.

LEGAL PRINCIPLES “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft

2 In deciding a motion to dismiss, the court “accept[s] all factual allegations as true and draw[s] all reasonable inferences in favor of the plaintiff.” Trs. of Upstate N.Y. Eng’rs Pension Fund v. Ivy Asset Mgmt., 843 F.3d 561, 566 (2d Cir. 2016). The following facts are taken from the complaint, Docket Item 1. v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “The plausibility standard is

not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. (quoting Twombly, 550 U.S. at 556). DISCUSSION

I. FAILURE TO STATE A CLAIM To establish a claim for retaliation under section 1983, a plaintiff must show “(1) that the speech or conduct at issue was protected, (2) that the defendant took adverse action against the plaintiff, and (3) that there was a causal connection between the protected speech and the adverse action.” Espinal v. Goord, 558 F.3d 119, 128 (2d Cir. 2009) (quoting Gill v. Pidlypchak, 389 F.3d 379, 380 (2d Cir. 2004)). Squires argues that Rivers has failed to state a retaliation claim because the complaint does not plausibly allege a causal connection between a protected activity— Rivers’s report—and an adverse action.3 Docket Item 17-1 at 4-9. Rivers responds that

3 Squires also suggests that the complaint fails to plead that Rivers suffered an adverse action. See Docket Item 17-1 at 6 (“Because the reporting of the alleged sexual abuse is a protected activity, this Court need only to consider the latter two elements.”). But Squires does not actually argue that either solitary confinement or a transfer resulting in a longer prison sentence are not adverse actions. See generally Docket Item 17-1. And as the case law cited by Rivers establishes, those actions clearly are adverse. See Docket Item 22 at 4-5 (collecting cases). Rivers therefore has adequately pleaded the second element of a retaliation claim. the complaint raises a plausible inference of retaliatory motivation. Docket Item 22 at 3- 7. This Court agrees with Rivers. As a threshold matter, Squires argues that Rivers’s allegations of retaliatory motive are “wholly conclusory” because Rivers “fails to include any dates or any other

specificity that links her alleged confinement” to her report. Docket Item 17-1 at 8. Rivers responds that “she was immediately sent to solitary confinement after being taken to the hospital for a rape kit” and that “approximately a week later she was transferred to [Bedford].” Docket Item 22 at 4. Rivers also notes that while she believes amendment is “unnecessary,” she could amend the complaint “to clarify the short timeline involved.” Id. at 3 n.1. But the facts of the complaint raise a plausible inference that Rivers was confined and transferred right after her report. See Docket Item 1 at ¶¶ 55-56 (alleging that after Rivers reported the rape, she “was placed in solitary confinement” and then “transferred to Bedford”). The Court therefore agrees with Rivers that amendment is unnecessary.

And a period of several days between a protected activity and an adverse action easily supports an inference of causal connection. See, e.g., Wright v. Snyder, 2023 WL 6379451, at *11 (D. Conn. Sept. 30, 2023) (“The Second Circuit has held that an adverse action occurring ‘just days’ after the plaintiff’s protected activity raises a genuine dispute of fact about the causal connection.” (quoting Bennett v. Goord, 343 F.3d 133, 138 (2d Cir. 2003)). In fact, periods of up to six months can show causation, see Espinal, 558 F.3d at 129, and there is no colorable argument here that more than six months elapsed between Rivers’s report and her confinement and transfer because Rivers was released from DOCCS custody five months after the sexual assault, see generally Docket Item 1. Squires also argues that Rivers cannot show retaliatory motive because there is a non-retaliatory explanation for the challenged actions. Docket Item 17-1 at 6-9. More

specifically, Squires asserts that Rivers was isolated and transferred for Rivers’s protection. Id. Squires explains that under the Prison Rape Elimination Act and related regulations and DOCCS directives, an official who learns that an inmate “is subject to a substantial risk of imminent sexual abuse . . . must take immediate steps to protect the incarcerated individual.” Docket Item 17-1 at 6-8.

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Bell Atlantic Corp. v. Twombly
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Ashcroft v. Iqbal
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Gill v. Mooney
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Rivera v. Senkowski
62 F.3d 80 (Second Circuit, 1995)
Bennett v. Goord
343 F.3d 133 (Second Circuit, 2003)
Mckenna v. Wright
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Espinal v. Goord
558 F.3d 119 (Second Circuit, 2009)
Brandon v. Kinter
938 F.3d 21 (Second Circuit, 2019)
Locurto v. Safir
264 F.3d 154 (Second Circuit, 2001)

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Bluebook (online)
Rivers v. Squires, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivers-v-squires-nywd-2024.