Williams v. Ritts

CourtDistrict Court, W.D. New York
DecidedFebruary 21, 2025
Docket1:22-cv-00254
StatusUnknown

This text of Williams v. Ritts (Williams v. Ritts) 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
Williams v. Ritts, (W.D.N.Y. 2025).

Opinion

KE FILED Cor UNITED STATES DISTRICT COURT S “py WESTERN DISTRICT OF NEW YORK FEB 21 2025 Map we Wye XC. Loewenguin 2 wh ISIAH WILLIAMS, STERN pistRICT Plaintiff, Vv. 22-CV-254 (JLS) JAMES B. RITTS, TODD BAXTER, MARK E. MONAGHAN, PATRICK PHELAN, DANIEL LUFFMAN, SCOTT PETERS, J.R. HUFFMAN, and INVESTIGATOR SHAFFER, Defendants.

DECISION AND ORDER

Pro se Plaintiff, Isiah Williams, is a prisoner confined at the Orleans Correctional Facility. He filed this action seeking relief under 42 U.S.C. § 1983, alleging that his arrest, prosecutions, and convictions in Ontario County, New York—which were subsequently reversed and dismissed—occurred in violation of his constitutional rights. Dkt. 1. The Court denied Williams’s motion to proceed in forma pauperis (“IFP”) because Williams had garnered “three strikes” under 28 U.S.C. § 1915(g), and he did not allege that he was in “imminent danger of serious physical injury.” Dkt. 5, at 2 (quoting 28 U.S.C. § 1915(g)). Williams moved to amend the Complaint, to allege imminent danger, and for reconsideration of the order denying his IFP motion. Dkt. 6.

The Court granted Williams leave to amend because his time to file an amended complaint as a “matter of course” had not expired. Dkt. 8, at 3, 5 (quoting Fed. R. Civ. P. 15(a)(1)(A)—-(B)). But the Court declined to reconsider the order denying his IFP motion because the Amended Complaint did not allege “imminent danger ... ‘fairly traceable to [the] unlawful conduct’... .” Dkt. 8, at 9 (quoting Pettus v. Morgenthau, 554 F.3d 298, 298 (2d Cir. 2009)). The Court provided Williams with additional time to pay the filing and administrative fees (Dkt. 8, at 12), which he did, and the Court proceeded to screen Williams’s Amended Complaint under 28 U.S.C. § 1915A. Dkt. 11. Upon screening, the Court liberally construed the Amended Complaint as asserting claims of malicious prosecution, false arrest and imprisonment, and denial of a fair trial based on allegations of “fabricated and manufactured evidence” and the lack of probable cause supporting Williams’s arrest and prosecution. Dkt. 11, at 4-5. The Court concluded that, while the false arrest claims would survive screening, it appeared that they were untimely and would be dismissed unless Williams showed cause as to why he was entitled to statutory or equitable tolling of the applicable three-year statute of limitations. Dkt. 11, at 16—20, 34-35. The Court further dismissed the claims against Defendants James R. Ritts, Mark E. Monaghan, and Todd Baxter pursuant to 28 U.S.C. § 1915A. Dkt. 11, at 10-14, 34-35. Additionally, the Court directed that the malicious prosecution and denial of fair trial claims against Patrick Phelan, and the failure to intervene claims against Scott Peters and Investigator Shaffer, proceed to service. Dkt. 11, at 14-26,

27-29, and 32-35. Lastly, the Court dismissed the claims against Defendant J.R. Huffman, except the false arrest claim, pursuant to 28 U.S.C. § 1915A. Dkt. 11, at 29-32, 34-35. The Court also deferred service until Williams responded to the Court’s order, dated April 1, 2024. Dkt. 11, at 34. Williams responded (Dkt. 12) and moved for service of the summons and Amended Complaint. Dkt. 13.1 Because Williams has raised plausible arguments that his false arrest claims are not barred by the applicable statute of limitations, the Court determines, in the interest of justice, that the false arrest claims should proceed to service, and Defendants be afforded the opportunity to address these arguments, or others, in their responses to the Amended Complaint or during summary judgment. See Benitez v. Wolff, 907 F.2d 1293, 1295 (2d Cir. 1990) (per curiam) (“Sua sponte dismissal of a pro se complaint prior to service of process is a draconian device, which is warranted only when the complaint lacks an arguable basis either in law or in fact. Where a colorable claim is made out, dismissal is improper prior to service of process and the defendants’ answer.”) (internal citations and quotation marks omitted). Further, Williams’s motion for an order directing the United States Marshals Service (“USMS”) to serve the summons and Amended Complaint (Dkt. 18) is granted. The USMS shall serve the summons and Amended Complaint upon Defendants, once Williams pays the service fees. See Fed. R. Civ. P. 4(c)(8).

1 Williams also moved for service a second time on December 20, 2024. See Dkt. 14.

DISCUSSION I. STATUTE OF LIMITATIONS: FALSE ARREST CLAIMS In screening the Amended Complaint, the Court concluded that Williams’s false arrest claims, while sufficiently pled to proceed to service, were barred by the statute of limitations because “[a] section 1983 claim ‘seeking damages for a false arrest in violation of the Fourth Amendment, where the arrest is followed by criminal proceedings, begins to run at the time the claimant becomes detained pursuant to legal process.” Dkt. 11, at 16-17 (quoting Wallace v. Kato, 549 U.S. 384, 397 (2007)). Here, Williams was arrested more than thirteen years before he filed this action, namely on or about May 28, 2008. Dkt. 11, at 17. Williams was, however, provided an opportunity to respond to this Court’s order—particularly as to why his false arrest claims should not be dismissed as untimely—because a court must provide a plaintiff with notice and an opportunity to respond before sua sponte dismissing a complaint on statute of limitations grounds. See Dkt. 11, at 34; see also Abbas v. Dixon, 480 F.3d 636, 640 (2d Cir. 2007); Zerilli-Edelglass v. N.Y.C. Transit Auth., 333 F.3d 74, 80 (2d Cir. 2003) (equitable tolling of the statute of limitations is applied only “in rare and exceptional circumstances in which a party is prevented in some extraordinary way from exercising his rights”) (cleaned up). In his response, Williams asserts that, under Heck v. Humphrey, 512 U.S. 477 (1994), his false arrest claims did not accrue until his conviction was reversed and the indictment dismissed on May 15, 2009, and that he is entitled to equitable tolling of the statute of limitations because he was “pursuing [the] dismissal of [his]

conviction ... between May 28, 2008 [and] May 15, 2019.” Dkt. 12, at 1. Williams claims that, because his false arrest claims “did not accrue[] until the criminal proceeding [was] terminated in [his] favor [on] May 15, 20[1]9,” his action under 42 U.S.C. § 1983 “for damages attributable to an unconstitutional conviction or sentence d{id] not accrue until the conviction or sentence [was] invalidated ... .” Dkt. 12, at 2. His Complaint was filed on March 29, 2022, within three years of the dismissal of his indictment. Dkt. 12, at 2—3; Dkt. 1.

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Related

Pettus v. Morgenthau
554 F.3d 293 (Second Circuit, 2009)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Henry Benitez v. D. Wolff, J. Kihl
907 F.2d 1293 (Second Circuit, 1990)
Abbas v. Dixon
480 F.3d 636 (Second Circuit, 2007)
Meilleur v. Strong
682 F.3d 56 (Second Circuit, 2012)

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Bluebook (online)
Williams v. Ritts, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-ritts-nywd-2025.