Cintron v. Doldo
688 F. App'x 44
| 2d Cir. | 2017Background
- Plaintiff Melvin Cintron, pro se, sued under 42 U.S.C. § 1983 after breaking his arm when he ran into a chair left on a prison baseball field.
- Cintron named a recreation staff member (Mattraw) and other prison officials as defendants, alleging Eighth Amendment violations for failure to remove the chair.
- The district court sua sponte dismissed the complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A for failure to state a claim, after Cintron had already amended once and sought no viable further amendment.
- Cintron appealed the dismissal to the Second Circuit challenging the dismissal and the denial of leave to amend.
- The Second Circuit reviewed the dismissal de novo and applied the familiar standards for plausible pleading and Eighth Amendment deliberate-indifference claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the chair on the baseball field constituted an objectively serious condition violating the Eighth Amendment | Cintron argued the chair posed an unreasonable risk that led to serious injury (broken arm) and thus violated his Eighth Amendment rights | Defendants implicitly argued the chair’s presence did not amount to a deprivation of basic human needs or a serious risk of harm | Court held the chair’s placement did not satisfy the objective element; not a deprivation denying minimal civilized measure of life’s necessities |
| Whether the recreation staff acted with deliberate indifference (subjective element) | Cintron contended staff (Mattraw) knew or should have known the chair posed a risk and disregarded it | Defendants argued, and record showed, no facts indicating Mattraw knew of and consciously disregarded an excessive risk | Court held Cintron failed to plead facts establishing deliberate indifference; allegations amounted at most to negligence |
| Whether dismissal without further leave to amend was proper | Cintron implicitly argued amendment could cure defects | Defendants (and district court) maintained Cintron had already amended and did not show how further amendment would cure defects | Court held denial of leave to amend was not an abuse of discretion because further amendment would be futile |
| Whether sua sponte dismissal under §§ 1915(e)(2)(B) and 1915A was proper | Cintron challenged dismissal as erroneous | Defendants supported dismissal for failure to state a plausible § 1983 claim | Court affirmed the sua sponte dismissal as proper under governing pleading standards |
Key Cases Cited
- Giano v. Goord, 250 F.3d 146 (2d Cir. 2001) (standard of review for sua sponte dismissal under § 1915(e)(2))
- Larkin v. Savage, 318 F.3d 138 (2d Cir. 2003) (per curiam) (sua sponte dismissal principles)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (application of plausibility and inference standards to complaints)
- Hill v. Curcione, 657 F.3d 116 (2d Cir. 2011) (special solicitude for pro se pleadings)
- Walker v. Schult, 717 F.3d 119 (2d Cir. 2013) (two-part Eighth Amendment test: objective and subjective elements)
- Helling v. McKinney, 509 U.S. 25 (1993) (societal standards and objective risk analysis under Eighth Amendment)
- Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (deliberate indifference requires more than negligence)
- Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (futility as justification for denial of leave to amend)