Washington v. Coixie Green State Prison

Background

Charmeen Denise Washington filed the action without a lawyer and was allowed to proceed without paying the filing fee in advance. She named Coixie Green State Prison, Temaine Hamilton, Sherraina S. Washington, and Ian Davis as defendants. The court understood “Coixie Green State Prison” to refer either to Coxsackie Correctional Facility or Green Haven Correctional Facility.

Washington alleged that the defendants violated “The rights to Bair Arms, Civil Rights in General, Identity theft.” Her allegations also referred to attempted and completed rape, disclosure of her name and an address, a knife taken from an evidence room, failure to direct her to a police precinct, illegal implants, harassment, privacy violations, segregation, vaginal tearing, job loss, and electrocution. She requested $2.4 trillion in damages to be distributed to her family and the United States through the United Nations.

Jurisdiction

The court explained that federal district courts generally have jurisdiction over claims arising under federal law or over state-law claims between citizens of different states when the amount in dispute exceeds $75,000. Merely stating that a case involves a federal question does not establish federal jurisdiction; the complaint must allege facts showing a viable federal claim.

The court found that Washington had not alleged facts demonstrating a viable federal claim. It therefore concluded that federal-question jurisdiction was absent. The court also found that the complaint indicated Washington and the defendants were all from New York, which prevented the complete difference in state citizenship required for diversity jurisdiction. Because Washington did not allege a valid federal claim and the parties were not diverse, the court concluded that it lacked jurisdiction over any state-law claims as well.

Leave to Amend

Courts generally give a self-represented plaintiff an opportunity to amend a defective complaint, but they may deny that opportunity when amendment would be futile. The court denied Washington leave to amend because she had not pleaded facts suggesting any basis for subject-matter jurisdiction.

Related Filing Restriction

The court noted that, in an earlier round of related litigation, it had directed Washington to explain why she should not be barred from filing additional civil actions without paying the filing fee and prior permission. After she did not submit the required declaration, the court barred her from filing future civil actions without paying the filing fee in that court unless she first obtained permission. The court stated that this action had been filed before that bar order was issued.

Disposition

The court dismissed Washington’s complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The clerk was directed to enter judgment. The opinion does not state that the dismissal was with or without prejudice.