WILLIAM H. PAULEY, III, District Judge.
Plaintiff
The following facts are gleaned from the Complaint and presumed true for the purposes of this motion. On March 21, 2016 the Department of Corrections transported Haywood from New York County Supreme Court to Rikers Island. (Compl. ¶ 8.) A correction officer handcuffed Haywood and utilized a "black box," which is a device that is placed over the wrists to prevent prisoners from picking the handcuff locks. (Compl. ¶ 9.) Haywood, who had previously experienced discomfort from the black box due to the circumference of his wrists, informed the officer that the device was too small for his hands. (Compl. ¶ 9.) The officer responded that she was aware of his earlier issues with the black box, but that she had been ordered to use the device even though it was "very tight on [Haywood's] wrist." (Compl. ¶ 10.)
Haywood claims that the black box cut off circulation to his hands and caused swelling in his fingers. (Compl. ¶ 11.) Correction officers removed the device promptly upon Haywood's arrival at Riker's Island and "immediately" informed the intake guard of Haywood's discomfort. (Compl. ¶¶ 12-13.) Haywood declined medical attention at the time, informing the officers that "if it gets worse, I will report to sick call." (Compl. ¶ 14.)
Later that evening, Haywood went to the prison clinic with numbness in his hands and received 400 milligrams of Motrin. (Compl. ¶¶ 15-16.) He alleges that he still cannot bend one finger at the tip. Subsequently, a physician exempted Haywood from the black box device during transport. (Compl. ¶¶ 17-18.)
"[T]he sufficiency of a complaint is a matter of law that the court is capable of determining based on its own reading of the pleading and knowledge of the law."
When a party is proceeding
Haywood brings his federal civil rights claims under 28 U.S.C. § 1983 and
Although Haywood does not specifically allege how the City caused a violation of his constitutional rights, this Court gleans two theories from the Complaint. First, Haywood claims that the use of the black box constituted excessive force. Alternatively, Haywood alleges that the corrections officers acted with deliberate indifference to his health by applying the device despite knowing of his previous problems with the black box.
In analyzing an excessive-force claim, the "core judicial inquiry" is "whether force was applied in a good faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm."
The Complaint belies any allegation that correction officers acted with the requisite "wanton" state of mind when they applied the black box to Haywood's wrists. Haywood repeatedly alleges that the officer transporting him was well aware—even concerned—about his discomfort with the device. The officer "noted that the box was very tight" and, upon arrival at Rikers Island, "immediately let the intake guard know about [Haywood's] swollen hands and need for medical attention." (Compl. ¶¶ 10, 13.) This reasonable application of the restraints, which the officer had been "ordered" to utilize, cannot give rise to a claim for excessive force.
"Deliberate indifference to serious medical needs of prisoners . . . constitutes the unnecessary and wanton infliction of pain . . . proscribed by the Eighth Amendment."
Haywood's deliberate-indifference claims fail for substantially the same reasons as his excessive-force allegations. The facts in the Complaint demonstrate that the corrections officers were well aware of his discomfort and took prompt, reasonable steps to remove the black box as soon as possible. The officers also offered Haywood medical attention, which he declined. This suggests anything but a conscious disregard for an excessive risk to Haywood's health and safety; indeed, it appears from the allegations in the Complaint that the Rikers Island staff, constrained by a directive to utilize the black box, did everything possible to alleviate Haywood's discomfort and mitigate any resulting injuries. Thus, Haywood has not stated a claim for deliberate indifference to his medical needs.
Because this Court finds that Haywood has failed to allege a violation of any constitutional right, he cannot state a claim for
Haywood also brings state-law negligence claims against the City. A federal court "may decline to exercise supplemental jurisdiction over a [pendent state law claim]" if the court "has dismissed all [federal] claims over which it has original jurisdiction." 28 U.S.C. § 1367(c)(3). "Needless decisions of state law should be avoided both as a matter of comity and to promote justice between the parties, by procuring for them a surer-footed reading of applicable law."
Defendant's motion to dismiss the Complaint is granted. Haywood's federal civil rights claims are dismissed with prejudice, and his state-law negligence claims are dismissed without prejudice. The Clerk of Court is directed to terminate all pending motions and mark this case as closed. The Clerk of Court is further directed to mail a copy of this Opinion and Order to the Plaintiff and note service on the docket.
SO ORDERED.