Jones-Bey v. The State of New York

Background

Sister E. Jones-Bey appeared without a lawyer and filed the action under the court's federal-question jurisdiction. The court had previously allowed her to proceed in forma pauperis (IFP), meaning without prepaying filing fees. She named the State of New York as the defendant.

The complaint stated, in general terms, that various government-related entities, agencies, officers, employees, and contractors had subjected her to violations of rights protected by the Constitution. It referred to Islam, her date of manifestation on Earth, and a most recent offense on October 2, 2024, but did not provide additional factual detail. She sought the return of all real property and finances held by the New York State Comptroller and one billion dollars in damages.

Court's analysis

The court applied the screening requirement for IFP complaints under 28 U.S.C. § 1915(e)(2)(B). That statute requires dismissal of an IFP complaint that is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant immune from such relief. The court also noted that it must dismiss an action when it lacks subject-matter jurisdiction.

The court held that the complaint violated Rule 8 of the Federal Rules of Civil Procedure because it did not provide a short and plain statement showing why Jones-Bey was entitled to relief. The general assertions that her rights had been violated were legal conclusions, and the complaint did not give enough facts for the court to understand what occurred or whether anyone could be legally responsible.

Because the complaint alleged constitutional violations, the court construed it as asserting a claim under 42 U.S.C. § 1983. Such a claim requires an alleged violation of a constitutional or federal-law right by a person acting under state authority. The court held that claims under § 1983 against the State of New York were barred by the State's immunity under the Eleventh Amendment. The court stated that New York had not waived that immunity and that Congress had not removed it through § 1983.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii)-(iii), with 30 days' leave to replead. The court allowed Jones-Bey to file an amended complaint explaining her claims and the events supporting them. If she did not file an amended complaint within the permitted period, the clerk would be directed to enter judgment. The court also certified that any appeal would not be taken in good faith and denied IFP status for purposes of an appeal. The clerk was directed to keep the matter open on the docket until a civil judgment was entered.