Bryceland V The City Of New York

Key Facts

Issues

• The court examined whether Bryceland's claim under Title II of the Americans with Disabilities Act states a viable claim. To state a viable Title II claim, a plaintiff must allege a disability, exclusion from or discrimination by a public entity, and that such exclusion or discrimination was due to the disability. Bryceland's allegation that officers' conduct triggered her PTSD does not state a cognizable disability, and she failed to allege that the City discriminated against her because of her PTSD, resulting in dismissal of the ADA claim.
• The court evaluated whether Bryceland has RICO standing to pursue her claim under the Racketeering Influenced and Corrupt Organizations Act. To state a civil RICO claim, a plaintiff must plead a violation of Section 1962, an injury to the plaintiff's business or property, and causation of the injury by the defendant's violation. Bryceland failed to plead a violation of Section 1962 and adduced no facts suggesting any defendant was involved in racketeering activity, resulting in dismissal of the RICO claim.
• The court assessed whether Bryceland's claim under 42 U.S.C. § 1985, which prohibits conspiracies to violate civil rights, is adequately pled. To plead a Section 1985 claim, a plaintiff must allege a conspiracy for the purpose of depriving persons of equal protection, an act in furtherance of the conspiracy, and resulting injury or deprivation of rights. Bryceland pleaded no facts supporting the existence of a conspiracy, relying entirely on conclusory assertions, which required dismissal of the Section 1985 claim.
• The court determined which Section 1983 claims for excessive force and false arrest may proceed. Bryceland's excessive force claim may proceed against Officers Masullo and Burns, while her false arrest and wrongful imprisonment claim may proceed against Officers Masullo and Burns. The claims are dismissed as against John/Jane Doe defendants because Bryceland never alleged that anyone other than Masullo and Burns used physical force or arrested her.
• The court evaluated whether the City and County of Richmond can be held liable under Section 1983. A municipality may not be held liable under Section 1983 solely because it employs a tortfeasor; instead, a plaintiff must identify a municipal policy or custom that caused the injury. Bryceland failed to plausibly allege the existence of any such policy or custom, and her arrest alone is insufficient to demonstrate municipal custom, resulting in dismissal of claims against the City and County.
• The court determined whether the six claims brought under Title 18 of the federal criminal code constitute valid private causes of action. The court concluded that Title 18 does not provide a private right of action unless the specific statute includes an express or implied private right of action, and none of the statutes invoked by Bryceland provide such a right, requiring dismissal of all six Title 18 claims.
• The court examined whether Bryceland's state-law negligence claim may proceed. A negligence claim against a municipality requires showing the municipality acted in a governmental capacity, owed a special duty to the injured party, or violated a statutory duty. Bryceland failed to allege a special duty or facts supporting one, and negligence claims cannot coexist with allegations of excessive force and false arrest against officers, resulting in dismissal of the negligence claim.

Holdings

Remedies

• The court permitted Bryceland's Section 1983 claims for excessive force and false imprisonment to proceed against Officers Masullo and Burns. The state-law negligence claim against the City and a Jane Doe 911 operator was also allowed to proceed. All other claims, including Title 18, RICO, ADA Title II, Section 1985, and claims against other defendants, were dismissed.
• The court granted Bryceland's motion to proceed in forma pauperis for this case. However, the court denied in forma pauperis status for purposes of an appeal, certifying that any appeal would not be taken in good faith pursuant to 28 U.S.C. § 1915(a)(3).

Legal Principles

Precedent Name

• Poe v. Leonard
• Coppedge v. United States
• Bell Atl. Corp. v. Twombly
• Fulton v. Goord
• Kiobel v. Royal Dutch Petroleum Co.
• Denney v. Deutsche Bank AG
• Bd. of Cnty. Comm'rs of Bryan Cnty. v. Brown
• Ashcroft v. Iqbal
• Gorman v. Rensselaer Cnty.

Cited Statute

• RICO claim alleging racketeering activity violation
• Civil rights claims under 42 U.S.C. § 1983
• Conspiracy claim under 42 U.S.C. § 1985
• Title 18 federal criminal code claims
• In forma pauperis action dismissal standards
• ADA Title II disability discrimination claim

Judge Name

Passage Text

• Bryceland fails to satisfy this standard. She alleges only that the officers' conduct 'triggered her Post Traumatic Stress Disorder.' At the outset, this allegation does not state a cognizable disability. Bryceland offers no details about the nature or duration of her PTSD, and courts 'regularly dismiss [ADA claims] that do not specify the nature, duration, or frequency of a disabling condition.'
• Bryceland has not pleaded a violation of Section 1962. She adduces no facts suggesting that any defendant was involved in any racketeering activity, let alone a pattern of such activity. Accordingly, she lacks 'RICO standing' and her claim must be dismissed.
• Bryceland's Section 1983 claims for excessive force and false arrest may proceed against Officers Burns and Masullo. All other claims are dismissed.