Manchanda v. Attorney Grievance Committee 1st Department
- James Oetken
- 1:25-cv-03935
- U.S. District Court · Southern District of New York
- 2
In Manchanda v. Attorney Grievance Committee 1st Department, Judge Swain dismissed the action without prejudice for violating a prior filing injunction.
Rahul Dev Manchanda’s action was dismissed without prejudice. The defendants were the Attorney Grievance Committee 1st Department and the NYS Supreme Court Appellate Division 1st Department. Manchanda was also denied fee-free appeal status.
What happened
Rahul Dev Manchanda filed this action against the Attorney Grievance Committee 1st Department and the NYS Supreme Court Appellate Division 1st Department. The Northern District of New York transferred it to the Southern District of New York because it was filed in the wrong district.
A prior order required Manchanda to obtain permission before filing a new action and to satisfy five filing requirements, including submitting a special motion, attaching the injunction, certifying that the claim was new, listing earlier related suits, and providing records of those suits. Although he paid the filing fee, he did not satisfy those requirements.
Chief Judge Laura Taylor Swain dismissed the action without prejudice for failing to comply with the prior order. She also denied fee-free appeal status, finding that any appeal would not be taken in good faith, and directed the Clerk to enter judgment.
The detailed version
- Manchanda v. Attorney Grievance Committee 1st Department · No. 1:25-cv-03935
- James Oetken
- May 16, 2025
Background
On February 5, 2024, Rahul Dev Manchanda was barred from filing an action in the Southern District of New York—or removing a case from state court—without first obtaining the court’s permission. The earlier order required him to file a motion with a specified title, attach the injunction and accompanying order, provide a declaration or sworn affidavit stating that the proposed claim had never previously been raised by him, list every suit he had previously brought in New York state or federal court against any defendant in the proposed case, and provide each listed complaint and a certified record of its disposition. The order warned that failure to meet these requirements would support summary dismissal.
Current filing
Manchanda filed this action in the Northern District of New York and paid the $405 filing fee. That court transferred the action to the Southern District of New York on May 12, 2025, after determining that it had been filed in the wrong district. The opinion states that Manchanda did not comply with the February 5, 2024 order by satisfying the five required steps.
Ruling
Chief Judge Laura Taylor Swain dismissed the action without prejudice because Manchanda failed to comply with the February 5, 2024 order. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and therefore denied fee-free appeal status. The court also directed the Clerk of Court to enter judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.