Donahue v. The New York City Transit Authority, 1:24-cv-06544

Plaintiff Eileen Donahue was attacked by a third party on a New York City subway platform and suffered serious injuries when pushed onto the tracks.
The New York City Transit Authority (NYCTA) owns and operates the subway system where the incident occurred.
Donahue claimed NYCTA failed to install proper physical safety barriers and failed to adequately train its personnel on responding to assaults.
Donahue brought claims under 42 U.S.C. § 1983 (for deprivation of her Fourteenth Amendment rights) and state-law negligence.
NYCTA moved to dismiss both claims, arguing the complaint failed to state a claim on which relief could be granted.
The Court considered only well-pleaded factual allegations as true for the purposes of the motion to dismiss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
§ 1983 Due Process Violation	NYCTA's failure to install barriers and train staff violated her Fourteenth Amendment rights.	No affirmative government action triggered a constitutional violation; only inaction alleged.	Dismissed; failure to allege affirmative, egregious conduct by state as required.
Monell (Municipal) Liability	NYCTA had a policy/custom and deliberate indifference to known danger on platforms.	No deliberate indifference; complaints show NYCTA took some preventive action.	Dismissed; no plausible allegation of deliberate indifference or custom causing harm.
Failure to Train	Lack of employee training led to violation of Donahue’s constitutional rights.	No showing of violation of established rights or difficult choices requiring training.	Dismissed; failure-to-train claim requires more than mere inaction.
Supplemental Jurisdiction Over State Negligence Claim	State law negligence claim should remain in federal court.	Should be dismissed if federal claims are dismissed.	Dismissed without prejudice; state court can hear the negligence claim.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility of relief)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for facial plausibility)
DeShaney v. Winnebago Cnty. Dep't of Soc. Servs., 489 U.S. 189 (state's failure to protect from private violence not a due process violation except in limited circumstances)
City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train—deliberate indifference standard)
Wray v. City of New York, 490 F.3d 189 (elements of municipal liability under § 1983)
Pena v. DePrisco, 432 F.3d 98 (affirmative government action and state-created danger doctrine)
Gibbons v. Malone, 703 F.3d 595 (inferences drawn in favor of plaintiff at motion to dismiss)