Chauncey Stewart, a/k/a Chonice Stewart v. Edward Castine, individually, Dean Laclair, individually, Matthew Gravelle, individually, Kevin Santo, individually, Todd Strack, individually, N. Johnson, individually, N. Young, individually, Benjamin Darrah, individually, and John and Jane Doe 1 through 10

Summary

The court granted the named defendants’ Rule 12(b)(6) motion in this 42 U.S.C. § 1983 action arising from an alleged use of excessive force against an incarcerated plaintiff and his subsequent criminal prosecution. The court dismissed the malicious prosecution and fair trial claims without prejudice because the plaintiff was already incarcerated on unrelated charges and therefore did not allege an actionable post-arraignment deprivation of liberty. The supervisory liability claim was dismissed with prejudice because standalone supervisory liability is not independently cognizable under Second Circuit precedent.

Holdings

1. A plaintiff who is already incarcerated on unrelated charges and remains incarcerated throughout the challenged prosecution does not suffer an actionable deprivation of liberty from being compelled to attend the related criminal proceedings. Stewart therefore failed to state a § 1983 malicious prosecution claim.
2. Stewart failed to state a § 1983 fair trial claim because he did not allege an actionable deprivation of liberty resulting from the prosecution while he was already incarcerated on unrelated charges.
3. Standalone claims for supervisory liability are no longer cognizable under § 1983 in the Second Circuit. A plaintiff must instead plead and prove that each defendant, through the defendant's own individual actions, violated the Constitution.

Questions Presented

1. Whether Stewart plausibly alleged the deprivation-of-liberty element required for a § 1983 malicious prosecution claim when he was already incarcerated on unrelated charges.
2. Whether Stewart plausibly alleged a § 1983 fair trial claim when he remained incarcerated on unrelated charges during the prosecution.
3. Whether standalone supervisory liability claims remain cognizable under § 1983 after Tangreti v. Bachmann.

Disposition

other