Saunders v. Cardali

Background

Marvin Saunders, who resides in South Carolina and is representing himself, brought this action concerning a closed state-court matter. The defendants are his former lawyers—Robert A. Cardali, Paris L. Jason, and Donte Mills—and the New York City Department of Citywide Administrative Services, referred to as Citywide.

Saunders had previously brought a state-court action involving an elevator injury. The state court concluded that Saunders was employed by Citywide and therefore was a “Special Employee,” allowed the City and Citywide to amend their answer to add a workers’ compensation defense, and granted their motion for summary judgment. Saunders later settled his claims in 2020 for $2,000,000, subject to various liens. He later filed a grievance concerning one of his lawyers and then brought this federal action seeking money damages.

The court construed Saunders’s allegations that his former lawyers acted “under color of state law” as claims under 42 U.S.C. § 1983, the federal civil-rights statute. Because Saunders was allowed to proceed without prepaying filing fees, the court screened the complaint under the statute requiring dismissal of claims that are frivolous, fail to state a claim, or seek relief from an immune defendant. The court also considered whether it had subject-matter jurisdiction, meaning legal authority to hear the claims.

Claims Against Citywide

The court dismissed the claims against Citywide under the Rooker-Feldman doctrine, which generally prevents federal district courts from acting as appeals courts reviewing state-court judgments. The court found that Saunders lost in state court, complained of an injury tied to that judgment, asked the federal court to review the state court’s finding that he was a Special Employee, and filed the federal action after the state-court judgment. The court therefore dismissed the claims against Citywide for lack of subject-matter jurisdiction.

Claims Against the Former Lawyers

The court dismissed Saunders’s Section 1983 claims against Cardali, Jason, and Mills for failure to state a claim. Section 1983 generally requires facts showing that a defendant acted under authority of state law. The court determined that the former lawyers were private parties, that Saunders did not allege that they worked for a state or other government body, and that his assertion that they acted under government authority was unsupported by factual allegations.

The court also dismissed any claim Saunders sought to bring under 18 U.S.C. § 242, a federal criminal statute concerning deprivation of rights under color of law. The court held that Congress did not create a private right to bring a civil lawsuit under that statute.

State-Law Claims and Leave to Amend

The court construed the complaint as asserting state-law claims against Saunders’s former lawyers concerning their representation of him in the state-court matter. It explained that federal jurisdiction based on different-state citizenship would require Saunders to allege both that he and the defendants are citizens of different states and that more than $75,000 is at stake. The court found that Saunders did not allege facts showing that the amount in controversy exceeded $75,000. It also found that the complaint did not clearly identify the state-law claims, when the relevant events occurred, or how the former lawyers violated state law.

The court granted Saunders 30 days’ leave to file an amended complaint detailing any state-law claims against Cardali, Jason, and/or Mills and providing specific supporting facts for each defendant. If Saunders does not file an amended complaint within the permitted time, the court stated that the Clerk will be directed to enter judgment in the action.

Disposition

The court dismissed Saunders’s claims against Citywide under the Rooker-Feldman doctrine for lack of subject-matter jurisdiction. It dismissed his claims against Cardali, Jason, and Mills for failure to state a claim and granted him 30 days’ leave to file an amended complaint asserting state-law claims against them. Chief Judge Laura Taylor Swain certified that any appeal would not be taken in good faith and denied Saunders permission to proceed without prepaying fees for an appeal. The court directed the Clerk to hold the matter open until a civil judgment is entered.