Slip Opinion
N.D.N.Y.2020Background
- Pro se plaintiff Anthony D. Amaker filed a complaint arising from events while incarcerated at Bare Hill Correctional Facility alleging violations under § 1983, § 1981, RLUIPA, the ADA, the Rehabilitation Act, and constitutional provisions (First, Eighth, Fourteenth).
- Key factual allegations: racial/religious harassment on arrival; denial/delay of Ramadan-related meals/services; slip-and-fall in shower on July 30, 2016 causing an injured/dislocated toe; an allegedly false misbehavior report issued after a clinic visit and resulting disciplinary confinement and loss of privileges for 30 days.
- Plaintiff names numerous DOCCS staff and supervisors (Ranney, Harmon, Coleman, Albert, Flint, Boyd, Benior, Yelich, Phelix, Barton, Russell/John Doe, Willet, Annucci, Bellnier, McCoy) and seeks declaratory, injunctive, and monetary relief.
- The court screened the complaint under 28 U.S.C. § 1915A and dismissed many claims for failure to state a claim, but allowed limited claims to proceed: (1) First Amendment free-exercise claim against Ranney; (2) First Amendment retaliation claims against Harmon, Coleman, and Albert; and (3) Eighth Amendment deliberate-indifference (medical) claims against Harmon, Coleman, and Albert.
- The court dismissed injunctive relief as moot because plaintiff was released, dismissed RLUIPA claims for monetary relief against state actors, dismissed ADA/Rehab Act claims against defendants in their individual capacities (with prejudice) and against DOCCS officials in their official capacities without prejudice, and dismissed a range of access-to-courts, mail, due-process, equal-protection, supervisory-liability, and other free-exercise claims for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Free-exercise (RLUIPA / First Amendment) | Ranney and others interfered with Nation of Islam religious practices (meal timing, distribution, class materials) and denied Ramadan meals | Defendants lacked specific, substantial burden allegations; supervisory/causal links not alleged | Free-exercise claim against Ranney survives screening; free-exercise/RLUIPA claims otherwise dismissed for failure to state a claim or (RLUIPA monetary relief) as barred against state officers |
| Retaliation | Harmon, Coleman, Albert issued a false injury report/retaliated after plaintiff refused to sign incorrect injury report | Defendants argue actions do not plausibly show protected conduct plus causal nexus or are legitimate prison actions | Retaliation claims against Harmon, Coleman, Albert survive screening for response |
| Medical deliberate indifference (Eighth Amendment) | Delay/denial of care for dislocated toe and lack of follow-up for knee/back conditions | Defendants argue no plausible allegation that they knew of or disregarded serious medical needs for knee/back; facts insufficient for some defendants | Medical indifference claims against Harmon, Coleman, Albert re: toe survive; claims regarding knee/back or against other defendants dismissed for failure to state a claim |
| Access-to-courts / free-flow-of-mail | Refusal to pick up/send mail (Russell/John Doe) prevented filing post-conviction motion; incoming mail (religious photos) allegedly withheld | Defendants note assertions show at most delay, not actual injury; content/number of mail incidents and causal link not alleged; policies unspecified | Access-to-courts and free-flow-of-mail claims dismissed for failure to allege actual injury or ongoing unjustified censorship |
| Due process (disciplinary hearing) | Flint, Boyd and others denied evidence/witnesses and deleted plaintiff's statements at hearing, causing wrongful disciplinary sanction | Defendants contend plaintiff received procedural protections and sanctions did not impose atypical hardship; excluded evidence may be nonessential | Due-process claims dismissed: 30-day sanction not shown to be atypical; plaintiff failed to show prejudice from procedural omissions |
| Equal protection / supervisory liability | Discriminatory treatment of Nation of Islam and medical denial based on race; supervisors (Annucci et al.) responsible for policies/management failures | Defendants argue allegations are conclusory, lack comparators, causal detail, or personal involvement under Colon | Equal-protection and supervisory claims dismissed for failure to plead purposeful discrimination or supervisory personal involvement |
| ADA / Rehabilitation Act | Plaintiff alleges disabilities (knee, back, herniated discs, sciatica) and denial of bus services/accommodations | Defendants argue plaintiff fails to plead a qualifying disability, notice/request for accommodation, or discriminatory denial; individual-capacity suits barred | ADA/Rehab Act claims against defendants in individual capacities dismissed with prejudice; official-capacity claims dismissed for failure to state a claim |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standards for plausibility pleading)
- Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions vs. factual allegations; supervisory liability limits)
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard requires knowledge of substantial risk)
- Sandin v. Conner, 515 U.S. 472 (liberty interest atypicality inquiry for disciplinary confinement)
- Wolff v. McDonnell, 418 U.S. 539 (due process protections in prison disciplinary hearings)
- Cutter v. Wilkinson, 544 U.S. 709 (RLUIPA applicability to prisoners’ religious exercise)
- Lewis v. Casey, 518 U.S. 343 (right of access to courts requires actual injury)
- Davis v. Goord, 320 F.3d 346 (prisoners’ First Amendment mail and access-to-courts jurisprudence)
- Chance v. Armstrong, 143 F.3d 698 (standards for Eighth Amendment deliberate indifference in Second Circuit)
- Washington v. James, 782 F.2d 1134 (Second Circuit on mail tampering and when few incidents may be actionable)