Randolph v. Goodman

Background

Jamein Rakin Randolph, proceeding without a lawyer, filed a 108-page submission concerning an apartment at 1595 Odell Street. The court said the filing contained mostly legal jargon and few facts about the events underlying the case. The court assumed that Randolph intended to sue Ramona L. Goodman, an attorney for PPC Residential LLC, because she represented Randolph’s landlord in a civil court matter in which Randolph was involved.

Randolph referred to the “Zodiac Constitution” of 1774, the United States Constitution, treaties of peace and friendship involving the United States and Morocco, the Cestui Que Vie Act of 1666, the Corpus Juris Secundum, and other legal doctrines. He also asserted claims or theories involving “quo warranto,” fiduciary breaches, unauthorized use of trust property, and trespass to chattels. The filing included an apartment lease and a schedule listing proposed fees for alleged conduct, including attempted eviction and trespass to chattels.

Jurisdiction analysis

The court applied Federal Rule of Civil Procedure 12(h)(3), which requires dismissal when a federal court lacks subject-matter jurisdiction—that is, legal authority to hear the case. It liberally interpreted Randolph’s filing because he was representing himself, but explained that self-represented pleadings still must provide a short and plain statement showing entitlement to relief.

The court found no federal-question jurisdiction. Randolph did not allege facts supporting a claim under 42 U.S.C. § 1983, which provides a way to bring certain constitutional-rights claims against people acting under state authority. In particular, he did not allege that Goodman acted under color of state law or that she deprived him of a constitutional right. The court also concluded that the other authorities Randolph cited did not create a federal cause of action or establish federal jurisdiction.

The court also found no diversity jurisdiction. Diversity jurisdiction generally requires the plaintiff and defendant to be citizens of different states. Randolph’s allegations that he was of Moorish and Yamasee Indigenous descent and was domiciled outside the United States did not establish diversity jurisdiction. He also did not plead facts establishing Goodman’s domicile, so the court could not determine that the parties were citizens of different states. The court noted that one submitted document listed a Yonkers, New York address for Goodman and that Randolph also appeared to be domiciled in New York; if both were New York citizens, diversity jurisdiction would not exist.

Disposition

The court dismissed the complaint for lack of subject-matter jurisdiction. It granted Randolph 30 days—until September 19, 2025—to file an amended complaint providing additional facts that could show federal jurisdiction. The order did not state that the dismissal was with or without prejudice. If Randolph failed to file an amended complaint by the deadline, the clerk was directed to enter judgment in favor of Goodman and close the case.

Judge Jennifer L. Rochon certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied permission to appeal without paying the required fees.