Brown v. Semple, 3:16-cv-01144

Plaintiff Kenya Brown, a Connecticut inmate, sought to amend his civil-rights complaint to add defendants and claims arising from mental-health treatment, transfers between Corrigan and Cheshire prisons, loss of dentures, and an alleged sexual relationship with a prison psychologist.
Brown filed the amended complaint as of right under Fed. R. Civ. P. 15(a)(1); the Court granted leave to amend and docketed the proposed amended complaint and a supplemental cover page adding Officer Aponte.
The amended complaint spanned 300 paragraphs and 59 pages (plus 115 pages of exhibits) and joined many unrelated claims and defendants arising at different facilities and times.
The Court reviewed the amended pleading under 28 U.S.C. § 1915(e)(2)(B) and Fed. R. Civ. P. 8 and 20, dismissing numerous claims for noncompliance with Rules 8/20, for being duplicative of other pending Brown actions, and for failing to state claims.
Surviving claims: (1) First Amendment retaliation claim against Dr. Gagne; (2) Eighth Amendment deliberate-indifference claims regarding mental-health and safety against a set of named defendants; (3) Fourteenth Amendment equal-protection claim against specified officials; and (4) a conspiracy claim against specified officials. Several motions (extra interrogatories, extension, protective order) were denied without prejudice or as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown may file an amended complaint	Brown sought leave to add defendants/claims and corrected a cover page omission	Defendants had not yet responded; procedural posture allows amendment as of right	Granted: amendment allowed under Fed. R. Civ. P. 15(a)(1) and supplemental cover page granted (Doc. No. 34)
Pleading sufficiency under Rule 8 and joinder under Rule 20	Brown alleged many events, parties, and causes of action across years/facilities	Defendants argued the pleading is prolix, confusing, and joins unrelated claims/defendants	Dismissed many claims for noncompliance with Rules 8 and 20; Court found complaint excessive and not the "short and plain" statement required
Prior pending/duplicative litigation doctrine	Brown included dental, lost-denture, and Dr. Coursen–related claims in this case	Defendants relied on other Brown actions litigating same claims	Dismissed duplicative claims (prior pending action favored resolution in later-filed cases where defendants already appeared)
Retaliation and conspiracy claims; failure to state claims	Brown alleged defendants used policies/acts to retaliate and conspired to block grievances and transfers	Defendants argued allegations were conclusory or lacked requisite factual detail/motive	Most retaliation and conspiracy claims dismissed for lack of specific facts; only Dr. Gagne retaliation claim survived as plausible

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (facial plausibility standard governing sufficiency of factual allegations)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading and rejection of "labels and conclusions")
Carr v. Dvorin, 171 F.3d 115 (2d Cir. 1999) (§ 1915 dismissal required regardless of paid filing fee)
Harris v. Mills, 572 F.3d 66 (2d Cir. 2009) (pro se complaints construed liberally but still must meet plausibility standard)
Salahuddin v. Cuomo, 861 F.2d 40 (2d Cir. 1988) (complaints may be dismissed for prolixity and failure to comply with Rule 8)
Adam v. Jacobs, 950 F.2d 89 (2d Cir. 1991) (prior pending action doctrine; first-filed suit generally has priority absent special circumstances)
Griffin v. Breckenridge, 403 U.S. 88 (1971) (§ 1985(3) requires class-based, invidiously discriminatory animus)
Ciambriello v. County of Nassau, 292 F.3d 307 (2d Cir. 2002) (conspiracy claims require specific factual allegations; conclusory assertions insufficient)
Dolan v. Connolly, 794 F.3d 290 (2d Cir. 2015) (courts treat prisoner retaliation claims with skepticism; require specific facts)
Gill v. Pidlypchak, 389 F.3d 379 (2d Cir. 2004) (elements of a First Amendment retaliation claim)