Nieblas-Love v. Diaz

Background

Pedro D. Nieblas-Love, proceeding without a lawyer, sued Ileana Diaz, Rekha Sha, John Englebert, and the New York City Housing Authority. Blanco’s Enterprises Group, Inc. was also listed as a plaintiff, but the complaint was signed only by Nieblas-Love. He invoked federal-question jurisdiction and alleged that the defendants violated his Fourteenth Amendment right to due process, although the court said the complaint did not clearly explain what the defendants had done or failed to do.

The court understood the complaint as challenging decisions by New York state courts after Nieblas-Love’s Article 78 petition concerning the Housing Authority’s determination that bids submitted by Blanco’s were nonresponsive to its requests for quotations. The state-court proceedings included a denial of the petition, a denial of a motion to vacate, an affirmance by the Appellate Division, First Department, and the New York State Court of Appeals’ denial of leave to appeal. Nieblas-Love sought monetary damages in the complaint.

Claims on Behalf of Blanco’s

The court held that Nieblas-Love could not appear without a lawyer on behalf of Blanco’s. Corporations, partnerships, and limited liability companies may not appear in federal court without counsel, and a person proceeding without a lawyer may not represent another party. The complaint therefore could not proceed on Blanco’s behalf through Nieblas-Love.

Rooker-Feldman Doctrine

The Rooker-Feldman doctrine is a rule that prevents federal district courts from reviewing and rejecting final state-court judgments in cases brought by state-court losers who claim injury from those judgments. The court concluded that, to the extent Nieblas-Love was challenging the final state-court decisions and seeking relief that would require this court to vacate them, his claim was barred by that doctrine. This was a subject-matter jurisdiction ruling, meaning the court concluded it lacked authority to review the state-court judgments.

Disposition

The court dismissed the complaint as barred by the Rooker-Feldman doctrine. It declined to allow amendment because it found that the defects could not be cured by amending the complaint. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. It directed the clerk to enter judgment.