Satchell v. Molina
- Gregory Woods
- 1:23-cv-11119
- U.S. District Court · Southern District of New York
- 2
In Satchell v. Molina, Judge Woods declined to treat John Satchell’s letter as an amended complaint and directed him about opposing dismissal.
John Satchell, whose letter was not accepted as an amended complaint; the City of New York, whose motion to dismiss remained subject to a possible opposition.
What happened
In Satchell v. Molina, John Satchell sent the court a letter that appeared to raise new class-action claims and repeated allegations from earlier letters. The court had previously denied his request to certify a class and told him he needed permission to file an amended complaint.
Because Satchell had not requested or received permission to amend, and because the new letter repeated earlier allegations, the court did not accept it as an amended complaint. The court instead directed him that he could file a letter opposing the City of New York’s motion to dismiss within the time previously ordered.
Judge Woods also directed the Clerk to send Satchell copies of the order and specified documents by certified mail. This order did not rule on the City’s motion to dismiss.
The detailed version
- Satchell v. Molina · No. 1:23-cv-11119
- Gregory Woods
- May 19, 2025
Background
The court received John Satchell’s letter, postmarked May 12, 2025. The letter appeared to be a new complaint asserting class-action claims and also repeated allegations from Satchell’s earlier letters.
The court referred to its April 28, 2025 order, which denied Satchell’s motion to certify a class. That earlier order also stated that Satchell had to request permission before filing an amended complaint containing new or additional allegations. The court cited decisions stating that a person representing himself cannot maintain a class action on behalf of other people.
Court’s Action
Satchell had not moved for permission to amend, and the court had not granted permission. The court also found that the latest letter simply repeated allegations from his previous letters. For those reasons, the court did not accept the filing as an amended complaint.
The court directed Satchell, if he chose to do so, to file a letter opposing the City of New York’s motion to dismiss. Under the court’s earlier order, he had four weeks from service of the City’s motion to file his opposition. The Clerk was directed to mail Satchell copies of this order, the April 28 order, and documents at Docket Nos. 38 and 39 by certified mail.
Disposition
The court did not accept Satchell’s letter as an amended complaint. It directed him regarding a possible opposition to the City’s motion to dismiss and ordered certified-mail service of specified documents. The order did not decide the motion to dismiss. Judge Gregory H. Woods issued the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.