Amaker v. Schiraldi
1:15-cv-04879
E.D.N.YSep 29, 2017Background
- Anthony D. Amaker, an African American state prisoner, alleges City probation and State DOC employees inserted and/or failed to correct false information in his parole file (presentencing report and COMPAS), harming his parole prospects.
- Key alleged errors: (1) mischaracterizing a 1979 arrest/1981 manslaughter matter as an adult conviction (including a mistaken "YO"/youthful offender designation); (2) false mental-health and alcohol-history statements in the presentencing report; and (3) erroneous Tier III disciplinary sanctions in COMPAS despite a 2013 state-court order to expunge them.
- Amaker claims the errors resulted from racial bias (training and systemic discrimination), and he seeks declaratory/injunctive relief and damages under 42 U.S.C. §§ 1981 and 1983, and a Supremacy Clause claim.
- Procedural posture: Amended complaint filed; City and State defendants moved to dismiss. Court previously dismissed certain claims and defendants; Bell was deceased and not substituted. Court reviews motions and sua sponte dismissal obligations under 28 U.S.C. §§ 1915(e)(2), 1915A(b).
- District court dismissed all claims: Supremacy Clause and claims against deceased defendant Bell with prejudice; other claims dismissed without prejudice. The court denied as moot a motion to revoke IFP status and certified any appeal not taken in good faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of a private right of action under the Supremacy Clause | Amaker contends defendants misapplied state law re: his juvenile/adult status, invoking Supremacy Clause relief | Supremacy Clause does not by itself create a private cause of action to enforce federal law | Dismissed: No standalone private right under the Supremacy Clause; plaintiff must rely on substantive federal law (e.g., § 1983) |
| § 1981 claim | Racially motivated mistreatment of records deprived Amaker of equal benefit of laws/proceedings | § 1981 protects contract rights; Amaker alleges no contract or contractual impairment | Dismissed: § 1981 inapplicable because no contract-making/enforcement claim alleged |
| Equal Protection (racial discrimination) | Defendants trained to view Black prisoners as untrustworthy; systemic/statewide racial disparity supports discriminatory intent | Allegations are conclusory and do not plausibly show purposeful discrimination against Amaker by named officials | Dismissed: Plaintiff failed to plead discriminatory purpose as to named defendants; statistics/generalized allegations insufficient |
| Due Process — (a) Parole denial/arbitrary decision; (b) Right to accurate parole-file information; (c) Confidentiality; (d) Intimate/family association; (e) "Stigma plus" defamation | (a) Parole denial relied on erroneous records; (b) inaccurate records were relied on by parole board; (c) disclosure of juvenile/mental-health records violated confidentiality; (d) errors burdened family relationships; (e) false statements stigmatized and caused liberty/status alteration | Defendants: parole is discretionary under NY law; minor errors do not render denial arbitrary; State could rely on city presentencing report; alleged harms are speculative or premised on state-law remedies; stigma claims lack the required "plus" injury | Dismissed: (a) parole denial not arbitrary given statutory balancing and many proper factors cited; (b) inaccuracies were minor/harmless and State reasonably relied on city report; (c) disclosure did not "shock the conscience"; (d) no allegation of intent or specific associations; (e) no non-speculative "plus" injury imposed by defendants |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: factual allegations must plausibly suggest liability)
- Bell Atlantic v. Twombly, 550 U.S. 544 (2007) (plausibility requirement for complaints)
- Hili v. Sciarrota, 140 F.3d 210 (2d Cir. 1998) (absolute immunity for probation officers preparing presentencing reports)
- Barna v. Travis, 239 F.3d 169 (2d Cir. 2001) (no liberty interest in parole itself under state law)
- Armstrong v. Exceptional Child Ctr., Inc., 135 S. Ct. 1378 (2015) (Supremacy Clause is not itself a source of a private right of action)
- Hayden v. Paterson, 594 F.3d 150 (2d Cir. 2010) (discriminatory purpose requirement for equal protection claims)
- Sadallah v. City of Utica, 383 F.3d 34 (2d Cir. 2004) ("stigma plus" defamation standard under the Due Process Clause)