Judge rules prior settlement does not bar claims in new lawsuit alleging separate assault at Rikers
BROOKLYN, NY – A federal judge has denied the City of New York’s motion to dismiss a lawsuit filed by Michael Megginson, a Rikers Island inmate who alleges he was brutally beaten by correction officers while incarcerated in 2022, ruling that a prior settlement agreement does not prevent him from pursuing his latest claims.
Key Points
- U.S. District Judge Nina R. Morrison ruled the City’s bid for summary judgment was premature.
- The court found a previous release signed by Megginson in an unrelated case did not clearly bar his new claims.
- The lawsuit accuses Rikers Island correction officers of assault, excessive force, and constitutional violations.
Judge denies City’s motion for summary judgment
In a memorandum and order issued this week, Judge Morrison rejected arguments from the City of New York and its Department of Correction officers that Megginson’s claims were barred by a general release he signed in a separate civil rights settlement.
The City had asked the court to dismiss the case under Rule 12(c) of the Federal Rules of Civil Procedure, or alternatively to grant summary judgment under Rule 56, arguing that Megginson waived his right to sue as part of an earlier case. Judge Morrison disagreed, writing that the record did not establish that the release applied to the new allegations and noting that Megginson signed it while incarcerated and without legal counsel.
“For the reasons set forth below, the motion is denied,” Morrison wrote in her ruling.
Two separate incidents at Rikers
According to court filings, Megginson, who was detained at Rikers Island, alleges that he was assaulted by correction officers on October 2022, suffering injuries that required hospitalization. He claims the attack involved multiple officers using excessive force without justification.
The City argued that Megginson had already resolved all potential claims through a settlement in a prior case, Megginson v. City of New York, filed in January 2022 in the Southern District of New York. That earlier lawsuit stemmed from a December 2021 incident at Rikers, in which Megginson alleged he was pepper-sprayed, beaten with batons, and denied medical attention.
Megginson contends the new assault occurred nearly a year later and involved a different group of officers, making it a separate claim not covered by the prior release.
Court finds release ambiguous and potentially unenforceable
Judge Morrison found the scope of the earlier release unclear and potentially invalid as applied to this case. Because both parties referenced evidence beyond the pleadings, the court treated the motion as one for summary judgment and determined that the factual record was insufficient to dismiss the case at this stage.
The court also noted Megginson’s pro se status when he signed the prior release and the absence of legal counsel during the settlement process, factors that may affect whether the agreement was entered into knowingly and voluntarily.
The ruling allows Megginson’s lawsuit—filed under 42 U.S.C. § 1983—to move forward against the City and the correction officers named as defendants, including Joshua Wigfall, Curtis Tucker, Roger Berrios, Freddie Larry, Durrell Wilson, Keron Guy, Jamal Dart, and “Jane” Phillips, as well as several unidentified officers.
Case continues toward discovery
With the City’s motion denied, the case will proceed into discovery, where Megginson and his attorneys will seek records, testimony, and surveillance footage related to the alleged assault.
The case is Megginson v. City of New York et al., 24-CV-115 (NRM) (MMH), pending in the U.S. District Court for the Eastern District of New York.
Tags: Brooklyn, Rikers Island, civil rights