Moments v. Warden Ada Pressley
1:24-cv-01865
S.D.N.Y.May 24, 2024Background
- Plaintiff, currently incarcerated at the Rose M. Singer Center on Rikers Island, filed a pro se action under 42 U.S.C. § 1983.
- She alleges that while held at the Robert N. Davoren Center (RNDC), her constitutional rights were violated by the facility’s warden.
- The original complaint named the defendant as "Warden (John Doe)," but records indicate the current warden is Ada Pressley.
- The Court granted Plaintiff’s request to proceed in forma pauperis (without prepayment of fees) but noted that this does not exempt prisoners from paying the full filing fee.
- The Court is obligated to screen prisoner complaints under the Prison Litigation Reform Act and to construe pro se pleadings liberally, but they must still comply with Rule 8 of the Federal Rules of Civil Procedure.
- The Court, recognizing Plaintiff’s intentions, amended the complaint to name Ada Pressley and the City of New York as defendants and directed notification and waiver of service.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiff's complaint properly identifies defendants | Action intended against RNDC Warden ("John Doe") | Not addressed (identity unknown) | Court amends complaint to name real warden (Ada Pressley) and City as defendants |
| Whether complaint states a claim for relief under § 1983 | Alleges policy/custom of unconstitutional practices | Not yet addressed | To be construed liberally; must survive screening under PLRA |
| Whether in forma pauperis status exempts Plaintiff from fees | Request to proceed without prepayment | Not contested | IFP granted but full fee still owed |
| Whether pro se complaint should be liberally construed | Plaintiff filed pro se, claims against institution officials | Not contested | Court applies liberal construction, interprets complaint broadly |
Key Cases Cited
- Harris v. Mills, 572 F.3d 66 (2d Cir. 2009) (pro se pleadings must be liberally construed)
- Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (courts must interpret pro se pleadings to raise the strongest claims suggested)
- Abbas v. Dixon, 480 F.3d 636 (2d Cir. 2007) (PLRA screening obligations for prisoner complaints)