347-787-6824New York, NY — December 8, 2025 — The LAW FIRM OF DAYREL SEWELL, PLLC, announced today that the United States District Court granted the defendants’ motion to dismiss in Seabrook v. City of New York, et al. The Court rejected all claims brought under 42 U.S.C. § 1983 against the City and individual Department of Correction officials.
Source: Morris & Dewett
In a written Opinion and Order dated August 4, 2025, the Court concluded there was no constitutional violation and dismissed the claims against the individual defendants; consequently, the plaintiff’s municipal liability claim against the City was also rejected. The Court held that the Department of Correction (“DOC”) acted pursuant to a binding state Sentencing and Commitment Order that committed the plaintiff to state custody and directed DOC to deliver him to the New York State Department of Corrections and Community Supervision. Under the governing New York statutes, DOC was required to effect the transfer and did not have discretion to release the plaintiff on its own.
Applying the Second Circuit’s Vives framework, the Court further determined that DOC was enforcing a state-mandated order, not implementing its own policy, defeating both the individual-capacity claims and the municipal liability claim. The Court then reiterated that a municipal liability claim cannot succeed absent an underlying constitutional violation, which was lacking here.
In addition, the Court found the pleadings did not plausibly allege personal involvement by the Commissioner defendants. The Court ruled that allegations based only on a Commissioner’s high position in the DOC hierarchy are insufficient to prove their individual involvement.
Case Information: Seabrook v. City of New York, et al., No. 24-cv-2029 (PKC), U.S. District Court (Opinion & Order filed August 4, 2025)
