Youngs v. Orange County Sherrifs Organization
7:22-cv-04918
S.D.N.Y.May 9, 2024Background
- Plaintiff Robert M. Youngs, proceeding pro se, filed claims against four correctional staff at Orange County Correctional Facility (OCCF) based on events occurring during his incarceration from October 2019 to December 2021.
- Key incidents include: (a) a December 2021 disciplinary hearing, where Plaintiff alleged he was denied the right to call witnesses, and (b) multiple 2020 incidents where Plaintiff claimed he was retaliated against for requesting grievance forms.
- Plaintiff brought claims under 42 U.S.C. § 1983 for denial of due process and retaliation, alleging false misbehavior reports and cell confinement were imposed for requesting grievances.
- The original complaint named the county and its sheriff; the court dismissed several claims but allowed amendment for due process and retaliation issues, upon which Plaintiff added factual allegations and named the involved officers.
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing both the due process and retaliation claims were legally insufficient.
- Judge Román granted the motion to dismiss but provided Plaintiff one final opportunity to amend his complaint, with specific instructions for a second amended filing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process right to call witnesses | Gessner denied right to call witness in disciplinary hearing | No deprivation of protected liberty interest; process was sufficient | Dismissed; Plaintiff failed both prongs |
| Retaliation by filing false misbehavior | Laudato retaliated for requesting grievance form | Report was due to incident itself, not protected activity | Dismissed; no causal link, insufficient |
| Retaliation via cell confinement | Della Pia & Mann retaliated after grievance requests | Mere mention of grievances not enough; causation not pled | Dismissed; conclusory, lack of detail |
| Leave to amend | Should be allowed further amendment | Amendment would be futile | Allowed final opportunity to amend |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the facial plausibility standard for pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (articulates plausibility pleading requirement)
- Sandin v. Conner, 515 U.S. 472 (1995) (defines when prison discipline implicates a liberty interest)
- Sira v. Morton, 380 F.3d 57 (2d Cir. 2004) (due process in prison disciplinary hearings includes right to call witnesses)
- Dawes v. Walker, 239 F.3d 489 (2d Cir. 2001), overruled on other grounds, 534 U.S. 506 (heightened scrutiny for prisoner retaliation claims and adverse actions)