Jackson v. Wilcox, 1:20-cv-00110

Plaintiff Raymond L. Jackson, a New York state prison inmate, sued under 42 U.S.C. § 1983 seeking injunctive relief to compel NYSP HQ to turn over documents he contends are exculpatory.
Claims asserted: due process violation for withholding exculpatory evidence (Brady claim), equal protection conspiracy to deprive life and liberty, and a failure-to-protect/fundamental-fairness due process theory.
The magistrate judge conducted an initial review and recommended dismissal for lack of subject-matter jurisdiction, concluding a FOIL-based claim alone cannot support § 1983 and a Brady claim would be barred by Heck v. Humphrey.
Plaintiff did not file objections to the magistrate judge’s report-recommendation and had sought appointment of counsel (denied by the magistrate since dismissal was recommended).
The district court reviewed the recommendation for clear error, adopted it in full, dismissed the complaint without prejudice, entered judgment for defendants, and closed the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of access to documents under NY FOIL states a § 1983 claim	Jackson contends withholding FOIL materials violated his due process and other federal rights	FOIL denial is a state-law matter and does not create a federal § 1983 claim	FOIL-based claims alone do not support § 1983; dismissal for lack of jurisdiction
Whether alleged Brady violation can proceed while underlying conviction stands	Jackson argues withheld exculpatory evidence violated Brady and entitles him to relief	Any relief would necessarily impugn the validity of his conviction	Claim barred by Heck v. Humphrey; cannot proceed absent overturned conviction
Whether case should be dismissed with prejudice and whether counsel should be appointed	Jackson sought relief and counsel	Defendants sought dismissal; magistrate denied counsel given recommended dismissal	Complaint dismissed without prejudice; appointment of counsel denied in light of dismissal

Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claim barred if success would invalidate a conviction)
Rankel v. Town of Somers, 999 F. Supp. 2d 527 (S.D.N.Y. 2014) (wrongful FOIL denial alone does not state a § 1983 claim)
Collins v. City of New York, 923 F. Supp. 2d 462 (E.D.N.Y. 2013) (FOIL denial is insufficient basis for § 1983 relief)
Hudson v. County of Dutchess, 51 F. Supp. 3d 357 (S.D.N.Y. 2014) (remedy for FOIL denial is state-law Article 78 relief)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings must be construed liberally)