Rodriguez v. Westchester County Department of Corrections

District Court, S.D. New York·Decided July 15, 2025·No. 7:23-cv-05265·Unknown

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: KEVIN RODRIGUEZ, Plaintiff, -against- 23-cv-5265 (NSR) WESTCHESTER COUNTY AND OPINION & ORDER OFFICER BRAVADO, Defendants.

NELSON S. ROMAN, United States District Judge: Pro se Plaintiff Kevin Rodriguez (“Rodriguez or “Plaintiff’) initiated this action on June 20, 2023 (ECF No. 1), alleging deprivation of rights under 42 U.S.C. § 1983, claiming Eighth Amendment violations for excessive force and for deliberate indifference to medical needs, against Defendant Westchester County (“Westchester”) and Defendant Correction Officer Bravado (together, “Defendants”). Presently before the Court is Defendants’ Motion to Dismiss Pro se Plaintiff’s Second Amended Complaint pursuant to Federal Rules of Civil Procedure 12(b)(6). For the following reasons, Defendants’ Motion to Dismiss is GRANTED without prejudice. BACKGROUND The Court assumes familiarity with the facts in this case, as Plaintiff’s Second Amended Complaint pleads no new statements of fact. See, e.g., Rodriguez v. Westchester Cnty., No. 23-CV- 5265 (NSR), 2024 WL 4390222 (S.D.N.Y. Oct. 3, 2024) and Rodriguez v. Westchester Cnty., No. 23-CV-5265 (NSR), 2025 WL 1031371 (S.D.N-Y. Apr. 7, 2025)

PROCEDURAL HISTORY On June 20, 2023, Plaintiff commenced this action against the Defendants in his Complaint. (ECF No. 1.) On October 3, 2024, the Court issued an Opinion and Order dismissing the Complaint’s claims in its entirety, granting Plaintiff leave to file an Amended Complaint (Am.

Compl.”) (ECF No. 31.) Then, on November 7, 2024, Plaintiff filed his Amended Complaint. (ECF No. 33). Thereafter, on April 7, 2025, the Court issued an Opinion and Order dismissing the Amended Complaint in its entirety, granting Plaintiff leave to file a Second Amended Complaint. (ECF No. 38.) Plaintiff, on May 30, 2025, filed his Second Amended Complaint, which is the operative complaint. (ECF No. 40.) The Defendants filed their motion to dismiss and memorandum of law in support on June 26, 2025 (“Mot.”) (ECF Nos. 41 and 43.) Plaintiff did not file an opposition to Defendants’ motion, and thus Defendants did not file a reply in further support of their motion. LEGAL STANDARD A. Rule 12(b)(6)

Under Federal Rule of Civil Procedure 12(b)(6), dismissal is proper unless the complaint “contain[s] sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). When there are well-pled factual allegations in the complaint, “a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. at 679. While the Court must take all material factual allegations as true and draw reasonable inferences in the non-moving party’s favor, the Court is “not bound to accept as true a legal conclusion couched as a factual allegation,” or to credit “mere conclusory statements” or “[t]hreadbare recitals of the elements of a cause of action.” Id. at 678 (quoting Twombly, 550 U.S. at 555). The Second Circuit “deem[s] a complaint to include any written instrument attached to it as an exhibit or any statements or documents incorporated in it by reference . . . and documents that plaintiffs either possessed or knew about and upon which they relied in bringing the suit.” Rotham v. Gregor, 220 F.3d 81, 88 (2d Cir. 2000) (internal citations omitted). The critical inquiry

is whether the Plaintiff has pled sufficient facts to nudge the claims “across the line from conceivable to plausible.” Twombly, 550 U.S. at 570. A motion to dismiss will be denied where the allegations “allow[] the court to draw the reasonable inference that the Defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. B. Section 1983 Section 1983 provides, in relevant part, that “[e]very person who, under color of any statute, ordinance, regulation, custom, or usage, of any State . . . subjects, or causes to be subjected, any citizen of the United States . . . to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws shall be liable to the party injured.” Section 1983 “is not itself a source of substantive rights, but a method for vindicating federal rights elsewhere conferred by

those parts of the United States Constitution and federal statutes that it describes.” Baker v. McCollan, 443 U.S. 137, 144 n.3 (1979); see Patterson v. County of Oneida, 375 F.3d 206, 225 (2d Cir. 2004). To assert a claim under Section 1983, a plaintiff must allege “(1) the challenged conduct was attributable to a person who was acting under color of state law and (2) the conduct deprived the plaintiff of a right guaranteed by the U.S. Constitution.” Castilla v. City of New York, No. 09-CV-5446(SHS), 2013 WL 1803896, at *2 (S.D.N.Y. April 25, 2013); see Cornejo v. Bell, 592 F.3d 121, 127 (2d Cir. 2010). Therefore, a Section 1983 claim has two essential elements: (1) the defendant acted under color of state law, and (2) as a result of the defendant’ s actions, the plaintiff suffered a denial of his federal statutory rights, or his constitutional rights or privileges. See Annis v. County of Westchester, 136 F.3d 239, 245 (2d Cir. 1998); Quinn v. Nassau Cty. Police Dep’ t, 53 F. Supp. 2d 347, 354 (E.D.N.Y. 1999) (Section 1983 “furnishes a cause of action for the violation of federal rights created by the Constitution.”) C. Law of the Case Doctrine

The law of the case doctrine “holds that when a court has ruled on an issue, that decision should generally be adhered to by the court in subsequent stages unless cogent and compelling reasons militate otherwise.” Delville v. Firmenich Inc., 23 F. Supp. 3d 414, 425 (S.D.N.Y. 2014) (quoting United States v. Quintieri, 306 F.3d 1217, 1225 (2d Cir. 2002)). See also In re Peters, 642 F.3d 381 (2d Cir. 2011) (noting that while not binding the law-of-the-case doctrine counsels against a court revisiting prior rulings absent compelling reasons such as the need to correct a clear error or prevent manifest injustice); In re Currency Conversion Fee Antitrust Litig., 264 F.R.D. 100 (S.D.N.Y. 2010) (same). D. Pro Se Pleading Standard Where a litigant is pro se, the Court is empowered to consider “new facts raised in

opposition papers to the extent they are consistent with the complaint, treating the new factual allegations as amending the original complaint.” Davila v. Lang, 343 F. Supp. 3d 254, 267 (S.D.N.Y. 2018).

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