Coleman v. County of Suffolk, 685 F. App'x 69

Plaintiff Phyllis Coleman sued Suffolk County and multiple Suffolk County police officers under 42 U.S.C. § 1983 after her daughter, Santia N. Williams, was murdered by an estranged boyfriend, Jason Jenkins. Coleman alleged officer responses to 911 calls increased the risk Jenkins would harm Williams.
Coleman claimed officers’ statements and conduct during responses effectively sanctioned or increased the danger to Williams under the state-created danger theory of substantive due process.
The district court granted summary judgment to the officers and Suffolk County and declined supplemental jurisdiction over Coleman’s related state-law tort claims; Coleman appealed.
The Second Circuit reviewed de novo, viewing facts in Coleman’s favor and assuming familiarity with the record. Coleman did not press claims against some defendants, and the court did not address those further.
The record showed officers took affirmative actions against Jenkins (arrests on warrants, returning property, helping locate a child, reading an order of protection), and there was no evidence officers’ statements condoned violence or were made in Jenkins’s presence to signal official sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers’ conduct created state-created danger giving rise to substantive due process liability	Officers’ responses and statements to 911 calls increased Jenkins’s risk of harming Williams and amounted to official conduct sanctioning private violence	Officers did not affirmatively act to sanction or encourage violence; their actions were protective or neutral and included arrests and enforcing orders	No due process violation; summary judgment for officers affirmed
Whether Suffolk County is liable under municipal liability for the officers’ conduct	County’s policies/practices led to the officers’ conduct that increased risk to Williams	Municipal liability cannot attach where individual officers committed no constitutional violation	County not liable; summary judgment for Suffolk County affirmed
Whether district court abused discretion in declining supplemental jurisdiction over state-law claims after dismissing federal claims	Coleman sought jurisdiction over state claims if federal claims were viable	District court properly declined because federal claims were dismissed before trial	No abuse of discretion; declination affirmed

DeShaney v. Winnebago Cty. Dep’t of Soc. Servs., 489 U.S. 189 (state’s failure to protect private individuals generally does not violate due process)
Lombardi v. Whitman, 485 F.3d 73 (2d Cir.) (failure to protect or warn does not alone create due process liability)
Dwares v. City of New York, 985 F.2d 94 (2d Cir.) (state-created danger doctrine requires affirmative acts communicating sanction of private violence)
Leatherman v. Tarrant Cty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163 (stands for other procedural principles cited)
Pena v. DePrisco, 432 F.3d 98 (2d Cir.) (discusses state-created danger and affirmative conduct requirement)
Okin v. Vill. of Cornwall-on-Hudson Police Dep’t, 577 F.3d 415 (2d Cir.) (examples of officers’ conduct that could imply sanctioning an abuser)
Mitchell v. City of New York, 841 F.3d 72 (2d Cir.) (standard of review for summary judgment in § 1983 appeals)
City of Los Angeles v. Heller, 475 U.S. 796 (municipality not liable where individual officer inflicted no constitutional harm)
Curley v. Vill. of Suffern, 268 F.3d 65 (2d Cir.) (municipal liability analysis when plaintiff’s theory depends solely on individual officer conduct)
Barrett v. Orange Cty. Human Rights Comm’n, 194 F.3d 341 (2d Cir.) (municipal liability can arise from non-party conduct for which municipality is answerable)
Delaney v. Bank of Am. Corp., 766 F.3d 163 (2d Cir.) (abuse-of-discretion standard for district court’s decline of supplemental jurisdiction)