Rodriguez v. County of Suffolk
155 A.D.3d 915
| N.Y. App. Div. | 2017Background
- Plaintiff Angel Luis Rodriguez sued Suffolk County and officers under state law and 42 U.S.C. § 1983 for false arrest, malicious prosecution, failure to provide medical assistance, and municipal (Monell) liability.
- Plaintiff sought leave to amend his complaint to add two new § 1983 causes of action; the court denied leave as the proposed claims were palpably insufficient.
- Defendants moved for summary judgment; they relied on an accomplice’s sworn statement supporting probable cause for arrest and the fact that plaintiff was later indicted by a grand jury.
- Defendants also submitted evidence that plaintiff received medical attention (transport to hospital and insulin) while in custody.
- Supreme Court granted defendants’ cross motion dismissing all causes of action; plaintiff appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Leave to amend to add § 1983 claims | Amendment was permissible despite notice-of-claim omissions | New claims were insufficient on their face | Court: Denial on wrong procedural ground (notice) but affirmed because proposed claims were palpably insufficient |
| False arrest (state & § 1983) | Arrest lacked probable cause | Probable cause existed based on accomplice’s sworn statement | Court: Summary judgment for defendants — probable cause; no triable issue |
| Malicious prosecution (state & § 1983) | Prosecution lacked probable cause / was malicious | Indictment by grand jury creates presumption of probable cause | Court: Summary judgment for defendants — grand jury indictment raised presumption; plaintiff failed to rebut |
| Deliberate indifference / failure to provide medical care | Defendants failed to provide care for diabetic condition | Defendants provided medical care (hospital visit, insulin); no deliberate indifference | Court: Summary judgment for defendants — no triable issue of deliberate indifference |
| Municipal liability (Monell) | County policies/practices caused constitutional violations | No underlying constitutional violation shown | Court: Summary judgment for defendants — Monell claim fails because no constitutional violation shown |
Key Cases Cited
- Blake v. City of New York, 148 A.D.3d 1101 (App. Div. 2017) (a notice of claim is not a condition precedent to a § 1983 cause of action)
- Weyant v. Okst, 101 F.3d 845 (2d Cir. 1996) (probable cause is a complete defense to false arrest claims under § 1983)
- Colon v. New York, 60 N.Y.2d 78 (N.Y. 1983) (grand jury indictment creates a presumption of probable cause for malicious prosecution claims)
- Monell v. Department of Social Services, 436 U.S. 658 (U.S. 1978) (municipal liability under § 1983 requires a governmental policy or custom causing the constitutional violation)
- Savino v. City of New York, 331 F.3d 63 (2d Cir. 2003) (discussing indictment and malicious prosecution defenses)
- Segal v. City of New York, 459 F.3d 207 (2d Cir. 2006) (Monell requires proof of an underlying constitutional violation)
- Alfaro Motors, Inc. v. Ward, 814 F.2d 883 (2d Cir. 1987) (standard for evaluating whether proposed amendments are palpably insufficient)