Karelefsky v. Department of Corrections, 1:20-cv-09485

Plaintiff Matthew Karelefsky, incarcerated at Rikers Island, filed a pro se § 1983 action after being one of many detainees in an initial complaint about COVID-19–related unsafe conditions at the Vernon C. Bain Center.
The multi-plaintiff complaint was severed; Karelefsky’s claims were docketed separately and he signed an amended complaint that lacked specifics about defendants’ roles.
In his second amended complaint Karelefsky alleged inadequate mental-health and medical care (including denial of a CPAP), unconstitutional conditions of confinement, and improper restrictions on communications (blaming a state-court gag order and DOC personnel); he sought release and transfer to a psychiatric hospital.
Named defendants included DOC Commissioner Cynthia Brann, Health Director Patsy Yang, Board of Correction Executive Director Margaret Egan, and the New York City Department of Correction (DOC).
The Court held the DOC is not a suable entity, found no facts showing personal involvement by the named individuals (precluding supervisory liability), and ruled Younger abstention bars federal interference in the ongoing state criminal proceedings without a showing of bad faith or extraordinary circumstances.
The second amended complaint was dismissed under 28 U.S.C. § 1915(e)(2)(B); plaintiff was granted leave to file a third amended complaint within 60 days with specific pleading instructions; IFP for appeal denied as not taken in good faith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaints sufficiently plead individual defendants’ personal involvement	Karelefsky alleges denial of care and restrictions; names Brann, Yang, Egan and DOC	Defendants (and Court) note pleadings lack facts tying each individual to specific acts	Dismissed as to individuals for failure to plead personal involvement; must plead specific facts to hold officials liable
Whether DOC is a proper defendant	Plaintiff sues DOC as defendant responsible for conditions	DOC (and Court) asserts DOC is an agency not subject to suit under NYC Charter	DOC not a suable entity; claims against it dismissed
Whether federal court may intervene in pending state criminal proceedings (Younger)	Plaintiff seeks release and relief affecting ongoing state criminal matter	Defendants invoke Younger abstention to bar federal intrusion absent bad faith or extraordinary circumstances	Court declines to intervene under Younger; advises habeas ( §2254 ) after state remedies exhausted
Whether pleadings meet Rule 8/Twombly–Iqbal plausibility and screening under PLRA	Karelefsky contends allegations suffice to state constitutional violations	Court applies Twombly/Iqbal and PLRA screening (28 U.S.C. §1915A/§1915(e))	Second amended complaint dismissed for failure to state a plausible claim; leave to replead with detailed instructions granted

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim under Rule 8)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (courts separate legal conclusions from factual allegations when assessing plausibility)
Younger v. Harris, 401 U.S. 37 (1971) (federal courts ordinarily must abstain from interfering in pending state criminal proceedings)
Tangreti v. Bachmann, 983 F.3d 609 (2d Cir. 2020) (supervisory liability under § 1983 requires pleading official’s own misconduct or personal involvement)
Abbas v. Dixon, 480 F.3d 636 (2d Cir. 2007) (screening and dismissal standards for prisoner complaints)
Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (pro se pleadings must be read liberally but still meet Rule 8)
Harris v. Mills, 572 F.3d 66 (2d Cir. 2009) (liberal construction of pro se pleadings)
Diamond "D" Const. Corp. v. McGowan, 282 F.3d 191 (2d Cir. 2002) (Younger abstention elements)
Dove v. Fordham Univ., 56 F. Supp. 2d 330 (S.D.N.Y. 1999) (naming a defendant in the caption without alleging how they violated rights is insufficient)
Coppedge v. United States, 369 U.S. 438 (1962) (standard for good faith in seeking in forma pauperis appellate review)