Cannady v. Watson
- Laura Swain
- 1:24-cv-09300
- U.S. District Court · Southern District of New York
- 5
In Cannady v. Watson, Chief Judge Swain dismissed Cannady’s claims because Watson was immune from damages.
Vincent Cannady’s federal damages claims against Assistant United States Attorney RaeHan Watson were dismissed on immunity and frivolousness grounds. Any state-law claims were left undecided because the court declined supplemental jurisdiction, and Cannady was denied permission to proceed without prepaying fees for an appeal.
What happened
In Cannady v. Watson, Vincent Cannady, representing himself, sued Assistant United States Attorney RaeHan Watson for alleged malicious prosecution and false imprisonment. Cannady sought $2 million and based his allegations on events involving discovery, grand-jury materials, bail, medical records, and settlement negotiations in or related to his criminal case.
The court ruled that Watson’s alleged actions were part of his prosecutorial duties and closely connected to the criminal court process. Because prosecutors are protected from damages lawsuits for those actions, the court dismissed the federal claims as seeking money from an immune defendant and as frivolous. The court also declined to decide any state-law claims and denied permission to file another amended complaint.
Chief Judge Swain dismissed the action, directed the clerk to enter judgment, and denied permission to proceed without paying fees for an appeal after certifying that an appeal would not be taken in good faith.
The detailed version
- Cannady v. Watson · No. 1:24-cv-09300
- Laura Swain
- Apr. 14, 2025
Background
Vincent Cannady, who was detained at the Hudson County Correctional Center and represented himself, filed this action under Bivens v. Six Unknown Named Agents, a case allowing certain damages claims against federal officials for constitutional violations. He alleged that Assistant United States Attorney RaeHan Watson violated his federal constitutional rights. The court had allowed Cannady to proceed without prepaying the filing fee.
Cannady alleged that he was arrested by the Federal Bureau of Investigation on May 1, 2024, and charged with extortion, later reduced to attempted extortion. He described requests for discovery and grand-jury minutes, a proposed bail modification for medical treatment, Watson’s alleged use of medical records from the Department of Veterans Affairs, and an objection to the use of settlement negotiations in a criminal indictment. Cannady alleged malicious prosecution and false imprisonment and sought $2 million in damages.
Prosecutorial immunity
The court explained that prosecutors have absolute immunity from civil damages claims for actions within their official duties that are closely connected to the judicial phase of a criminal case. Although Cannady’s allegations were confusing, the court concluded that his references to discovery, grand-jury minutes, and bail concerned actions Watson took as an Assistant United States Attorney in connection with the criminal trial process.
The court therefore dismissed the claims because they sought monetary relief from a defendant immune from that relief. The court also characterized the claims as frivolous under the statutes governing cases filed without prepayment of fees.
State-law claims and amendment
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to decide related state-law claims, over any state-law claims Cannady might be asserting. The court also denied leave to amend because it determined that the defects could not be fixed by another amended complaint.
Disposition
The court dismissed the action, directed the clerk to enter judgment, and certified that any appeal would not be taken in good faith. It therefore denied Cannady permission to proceed without prepaying fees for an appeal.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.