Robert John Summa v. Thomas P. Urschel, Jennifer West, AmyLynn Roycroft, and Unknown Corrections Sergeants and Officers

Summary

The United States District Court for the Southern District of New York severed Robert John Summa’s claims concerning alleged inadequate medical care at Attica Correctional Facility from his claims concerning Woodbourne Correctional Facility. The court transferred the Attica-related claims to the Western District of New York and granted Summa 60 days to amend his Woodbourne-related claims against the remaining defendants. The court denied Summa’s request for pro bono counsel without prejudice.

Holdings

1. Claims arising at Attica and Woodbourne could not remain joined because they arose from different events, involved different defendants, and did not satisfy the requirements for joining multiple defendants under Rule 20.
2. The Attica claims were properly transferred to the Western District of New York because the relevant events occurred in Wyoming County, which is within that district, and transfer served the interest of justice.
3. The complaint failed to state a § 1983 claim for deliberate indifference to serious medical needs against Defendant Roycroft because it did not adequately allege either an objectively serious medical condition or that Roycroft acted with the required subjective culpability.
4. Plaintiff was entitled to 60 days to file an amended complaint addressing the deficiencies in his Woodbourne claims.
5. The request for pro bono counsel was denied without prejudice because Plaintiff had not demonstrated that his claims had merit and he was being granted leave to amend.

Questions Presented

1. Whether claims arising from alleged medical-care violations at Attica and Woodbourne Correctional Facilities could be joined in one action against separate defendants.
2. Whether the claims arising at Attica should be transferred to the Western District of New York for improper venue and the interest of justice.
3. Whether the complaint stated an Eighth Amendment deliberate-indifference claim under 42 U.S.C. § 1983 against the Woodbourne defendants.
4. Whether Plaintiff should be granted leave to amend the Woodbourne claims.
5. Whether Plaintiff's request for pro bono counsel should be granted.

Disposition

other