Williams v. Does
- Paul Engelmayer
- 1:24-cv-04794
- U.S. District Court · Southern District of New York
- 6
In Williams v. Does, Judge Engelmayer granted dismissal and dismissed the case with prejudice because Williams’s allegations did not state viable claims.
Jomo Williams’s claims against Erlon Hodge, Theresa Daniel, and unnamed state-court employees were dismissed with prejudice. His other pending requests were denied as moot, and the case was closed.
What happened
Jomo Williams, representing himself, sued state-court employees under a federal civil-rights law, claiming they denied him access to New York courts when they rejected filings submitted without a prior fee-waiver order. He sought orders requiring the employees to accept his filings, pausing deadlines, and $50 million in damages.
The court concluded that the employees were protected from damages claims brought against them in their official roles. It also found that Williams did not allege deliberate misconduct or actual harm needed for an access-to-courts claim, intentional discrimination needed for an equal-protection claim, or a legal basis for his remaining claims.
Judge Engelmayer adopted the magistrate judge’s recommendation, granted the motion to dismiss in its entirety, and dismissed the action with prejudice. The court denied Williams’s other pending requests as moot and closed the case.
The detailed version
- Williams v. Does · No. 1:24-cv-04794
- Paul Engelmayer
- Mar. 5, 2025
Background
Jomo Williams, proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against several state-court employees. He alleged that the employees violated the First and Fourteenth Amendments by denying him access to New York state courts. The two named defendants, Erlon Hodge and Theresa Daniel, moved to dismiss.
The dispute arose from Williams’s attempts to file state-court documents without paying filing fees in proceedings concerning an alleged failure to pay apartment rent. In June 2023, Daniel told Williams that he first needed a court order granting permission to proceed without prepaying fees. In June 2024, Hodge gave Williams the same information when he attempted another filing. Williams sought, among other relief, orders requiring the defendants to accept his filings, pausing deadlines and statutes of limitations in the underlying matter, and $50 million in damages.
Court’s analysis
The court reviewed Magistrate Judge Sarah L. Cave’s Report and Recommendation for clear error because Williams did not properly file timely objections. The court stated that, even if the attempted objections had been properly filed, they merely repeated arguments previously made to the magistrate judge.
The court held that the Eleventh Amendment barred damages claims against Hodge and Daniel to the extent they were sued in their official capacities as state-court employees. To the extent Williams sued them individually or sought injunctive relief, the court held that he failed to state a claim. For an access-to-courts claim, the court explained that a plaintiff must show deliberate and malicious conduct that caused actual injury. Hodge and Daniel had only informed Williams of the state courts’ requirement that a person obtain permission to proceed without prepaying fees.
The court also held that Williams did not plausibly allege intentional discrimination based on a protected characteristic for his equal-protection claim. It found that the state requirement applied evenly to people seeking to proceed without prepaying fees. The court further concluded that Williams’s remaining claims lacked an arguable legal basis and were frivolous.
Other requests and disposition
The court denied as moot Williams’s other pending requests, including requests for a temporary restraining order, a preliminary injunction, an order of protection, appointment of pro bono counsel, reconsideration, and permission to proceed without prepaying fees in this case and on appeal. The court had previously denied a separate emergency motion for a temporary restraining order for failure to state a claim.
Judge Paul A. Engelmayer adopted the Report and Recommendation in full, granted defendants’ motion to dismiss in its entirety, and dismissed the action with prejudice. The Clerk was directed to terminate all pending motions and close the case. The court also stated that the parties’ failure to properly object waived appellate review.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.