Rikers inmate loses lawsuit over cell search following stabbing incident
Brooklyn, NY — A Rikers Island detainee’s lawsuit against the City of New York and two correctional officers was tossed this week after a federal judge found that his constitutional rights were not violated during a post-stabbing cell search.
U.S. District Judge Ann M. Donnelly granted summary judgment to the City, Captain Fluker, and Correction Officer Hyde, rejecting pro se plaintiff Michael Hall’s claims that the March 2022 search of his cell at the Anna M. Kross Center (AMKC) amounted to an illegal search and seizure in violation of the Fourth and Fourteenth Amendments.
Cell searched after stabbing incident
According to court records, Hall was housed in Quad Upper 2 of the AMKC on Rikers Island when another inmate was stabbed during a violent altercation on March 9, 2022. In the immediate aftermath, correction officers conducted a series of searches for the weapon used in the attack, including a sweep of Hall’s cell.
Surveillance footage showed Hall being removed from his cell and officers taking a plastic bin, papers, and a bag into the hallway. Hall later returned and retrieved some of his belongings. He filed a 311 complaint later that day, stating that the officers “tore through his legal work” and failed to follow grievance procedures.
Hall filed suit in March 2023, amended it that September, and sought damages under Monell v. Department of Social Services, alleging constitutional violations by both the individual officers and the City of New York.
Court: No constitutional violation occurred
In her memorandum decision, Judge Donnelly found no evidence that the officers’ actions amounted to a constitutional violation.
The court emphasized that searches of inmate cells do not generally trigger Fourth Amendment protections, especially when prompted by security threats like inmate-on-inmate violence. The judge also noted that Hall failed to follow the required administrative grievance process under the Department of Correction’s Directive 3376R-A.
Although prison officials failed to respond to Hall’s 311 complaint within the mandated seven-day period, Hall also failed to appeal the non-response, and did not exhaust his remedies under the grievance system.
Claims dismissed, case closed
The court rejected all claims, including the Monell claim against the City, and dismissed the case with prejudice. Hall’s own motion for summary judgment, filed in December 2024, was denied.