Owner/Agent @dudeofnewyork v. The Unified Court System of The State of New York

Background

The plaintiff, who identifies as the Dude of New York and signed one submission as Damonte Brown, brought the case without a lawyer. The court had previously allowed the plaintiff to proceed without prepaying filing fees. The complaint named the Unified Court System of the State of New York, a New York State courthouse, New York State, the Chief Judge of the State of New York, a New York State Administrative Judge, a New York State Chief Clerk, and the United States Government.

The complaint did not provide facts supporting its claims. It said that supporting attachments had been provided, but no attachment was included. It referred to events involving Mount Sinai Health System, the plaintiff's hospitalization, and encounters with New York City police officers. The plaintiff did not explain what injuries he suffered or what relief he wanted. The court therefore could not determine whether the plaintiff intended to challenge his hospitalization or sue the police officers mentioned in the complaint.

Reasons for dismissal

The court dismissed the claims against the New York State court system, the New York courthouse, and New York State under the Eleventh Amendment, which generally protects states and their arms from federal lawsuits unless immunity has been waived or removed by Congress.

The court dismissed the claims against the Chief Judge and Administrative Judge under judicial immunity. That doctrine generally protects judges from damages claims based on actions taken as part of their judicial duties. The court found no facts suggesting that these judges acted outside those duties or without jurisdiction. The court also dismissed the claims against the New York State Chief Clerk under judicial or quasi-judicial immunity because the complaint did not suggest that the clerk's conduct was outside the judicial process.

The court dismissed the claims against the United States Government under sovereign immunity. That doctrine generally prevents lawsuits against the federal government unless the government has consented to be sued.

Failure to state a claim

Independently, the court held that the complaint failed to satisfy Rule 8 of the Federal Rules of Civil Procedure. Rule 8 requires enough factual detail to make a claim plausible and to show why the defendants may be legally responsible. Because the complaint did not state facts supporting a claim against a defendant who could be sued, the court dismissed it for failure to state a claim under the statute governing screening of complaints filed without prepaying fees.

Disposition

The court dismissed the complaint pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii), with 30 days' leave to replead. The plaintiff may file an amended complaint detailing the claims, and the court directed that the amended pleading be signed and include the plaintiff's real name in the caption and on the signature page. If no amended complaint is filed within the allowed time, the clerk will be directed to enter judgment. The court also certified that an appeal would not be taken in good faith and denied the plaintiff permission to proceed without prepaying fees for an appeal. The case was to remain open on the docket until judgment is entered.