Wright v. Bronx Criminal Court
1:24-cv-07923
S.D.N.Y.Jan 6, 2025Background
- Marcus Wright, a pro se plaintiff detained at Rose M. Singer Center (Rikers Island), filed a 42 U.S.C. § 1983 complaint alleging violations of her constitutional rights related to an April 2024 arrest in the Bronx.
- Wright claims unlawful arrest for alleged petit larceny, lack of access to property receipts, and inadequate assistance from both her court-appointed and current attorneys.
- Named defendants include the Bronx Criminal Court, NYC Department of Correction (DOC), the Ryer Avenue Police Precinct, Legal Aid Society and two attorneys, the Warden, and others.
- The federal court granted her request to proceed in forma pauperis but screened the complaint under the Prison Litigation Reform Act.
- The court evaluated whether the entities sued could be held liable under Section 1983 (governmental bodies, immune entities, or private actors), and reviewed their potential liability under both federal and state law claims.
- The court dismissed the complaint for failure to state a claim, while granting Wright 30 days to amend her claims to cure identified defects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eleventh Amendment Immunity for Bronx Criminal Court | Bronx Criminal Court violated her rights in connection with the criminal case | Court immune as an arm of the state; cannot be sued under § 1983 | Dismissed – barred by Eleventh Amendment |
| DOC and Ryer Avenue Precinct Suitability | DOC/NYPD agency actions violated rights | City agencies not suable entities under NY law; no municipal policy alleged | Dismissed – not suable; no policy/custom alleged |
| Warden’s Personal Involvement | Warden responsible for constitutional violations at Rikers | Insufficient facts alleging personal involvement | Dismissed – no facts to establish personal involvement |
| Private Actor Liability (Legal Aid, Attorneys) | Attorneys failed to assist, violating rights | Legal Aid and attorneys not state actors; not liable under § 1983 | Dismissed – private actors not subject to § 1983 |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets plausibility standard for complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must allege plausible claim to relief)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires policy/custom)
- Gollomp v. Spitzer, 568 F.3d 355 (2d Cir. 2009) (state courts are arms of the state and immune under Eleventh Amendment)
- Connick v. Thompson, 563 U.S. 51 (2011) (municipality liable only for its own policies)
- Spavone v. N.Y. State Dep’t of Corr. Serv., 719 F.3d 127 (2d Cir. 2013) (personal involvement required for § 1983 liability)