Quince v. Riker's Island Correctional Facility C-95 AMKC
1:18-cv-01010
| E.D.N.Y | May 19, 2020Background
- Plaintiff Jamal Quince (also spelled Jamaal Quince) filed a pro se civil-rights complaint alleging guard brutality (including possible use of chemical agents), negligent medical care, and food poisoning causing chronic rectal bleeding and a stomach infection at the Anna M. Kross Center (AMKC) on Rikers Island.
- The caption named “Rikers Island Correctional Facility C-95 AMKC” as defendant; the body of the complaint was internally inconsistent and also suggested a Bivens claim but facts point to a § 1983 action.
- Quince sought $9 million in actual and punitive damages and was granted in forma pauperis status for the purposes of the initial review.
- The court reviewed the complaint under 28 U.S.C. §§ 1915A and 1915(e)(2)(B) and found the pleading conclusory and lacking specific facts (e.g., dates, named individuals, specific acts) necessary to state plausible constitutional claims.
- The court dismissed the complaint for failure to state a claim but granted Quince 30 days to file an amended complaint specifying defendants, dates, locations, and factual allegations; dismissed claims against the Rikers facility as a non‑suable agency of New York City.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleading / failure to state a claim | Quince alleges guard brutality, medical negligence, and food poisoning; seeks damages | Complaint is conclusory, lacks dates, responsible individuals, and factual detail to make claims plausible | Complaint dismissed for failure to state a claim; leave to amend granted with instructions to plead specifics |
| Proper defendant / suability | Sued "Rikers Island Correctional Facility C-95 AMKC" | NYC DOC / Rikers is an agency and not a suable entity; suits against municipal agencies must be brought against City of New York and require municipal‑policy allegations | Claims against Rikers facility dismissed; may not substitute City absent allegations of an unconstitutional municipal policy or custom |
| Excessive‑force claim (guards/chemical agents) | Alleges guard brutality and possible use of chemical agents | Need to identify individual officers and factual circumstances (dates, acts) to state a § 1983 excessive‑force claim | Court held an excessive‑force claim might be viable if amended to name defendants (or John/Jane Does with identifying info) and provide specific facts and dates |
| Medical care / food poisoning (deliberate indifference) | Alleged negligent medical care and contaminated food caused serious injury | Negligence alone is insufficient; must plead serious medical need and that officials acted with deliberate indifference | Court explained Estelle/Farmer standard; such claims may proceed if amended to allege objective seriousness and officials' subjective deliberate indifference |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim based on factual content)
- Estelle v. Gamble, 429 U.S. 97 (1976) (medical malpractice rises to § 1983 only as deliberate indifference to serious medical needs)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires unconstitutional policy or custom)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate indifference standard)
- Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (court must grant leave to amend when complaint possibly can state a valid claim)
- Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (requirements for showing inadequate medical care under § 1983)
- Robles v. Coughlin, 725 F.2d 12 (2d Cir. 1983) (prisoners must be served nutritionally adequate, safe food)
- City of Oklahoma v. Tuttle, 471 U.S. 808 (1985) (single incidents generally insufficient to impose municipal liability without proof of a policy)