Falls v. Keenan

Background

Raiquan K. Falls, who was incarcerated at Green Haven Correctional Facility and was representing himself, brought the action under the court’s federal-question jurisdiction. He sued Edward Emmett Keenan, Keenan and Bhatia, LLC, Scott A. Korenbaum, and the Law Offices of Scott A. Korenbaum. According to the complaint, Keenan had volunteered to represent Falls for a jury trial in another civil case, and Korenbaum had been assigned to assist him.

Falls alleged that he and the defendants disagreed about several aspects of the legal strategy in that case. He claimed that the defendants primarily wanted him to settle so they could receive attorney fees or another financial benefit. After he rejected settlement offers, he alleged that the defendants said they would seek permission to stop representing him. Falls characterized the trial delays and communications about settlement as punishment for exercising his right to a trial. He asserted federal constitutional claims and state-law legal-malpractice claims and sought money damages.

Federal Claims

The court explained that Falls cited Bivens, which provides a potential remedy for certain constitutional violations by federal officials. Because Falls did not sue federal government employees, the court treated any constitutional claims as claims under 42 U.S.C. § 1983, the federal civil-rights statute for constitutional violations by persons acting under state law.

The court held that Falls did not state a § 1983 claim because the defendants were private parties and the complaint did not allege that they worked for a state or other government body. The court therefore dismissed the federal constitutional claims for failure to state a claim for relief.

State-Law Claims and Jurisdiction

The court treated Falls’s legal-malpractice claims as claims arising under state law. A federal court may hear such claims through diversity jurisdiction if the parties are citizens of different states and the amount in dispute exceeds $75,000. Falls alleged that he was incarcerated in New York, but he did not allege his domicile before incarceration. He alleged that Keenan’s law practice had offices in New York and Missouri and that Korenbaum had an office in New York, but he did not allege either defendant’s residential address. The court therefore found that the complaint did not establish that the parties were citizens of different states.

Falls sought $1.5 million in compensatory and punitive damages, but the court found it unclear from the alleged facts whether the malpractice claims were worth more than the $75,000 jurisdictional minimum. The court therefore concluded that it lacked diversity jurisdiction over those claims. Because it dismissed the federal claims, the court also declined to exercise supplemental jurisdiction—the court’s discretionary authority to hear related state-law claims—over any remaining state-law claims.

Leave to Replead and Disposition

The court granted Falls 30 days to file an amended complaint repleading his state-law legal-malpractice claims. The amended complaint must allege facts showing that the parties are citizens of different states and that the claims exceed $75,000. The court did not add a prejudice designation to the dismissal. If Falls does not file an amended complaint within the permitted time, the court stated that the Clerk will be directed to enter judgment.

Judge Louis L. Stanton’s order dismissed the complaint for failure to state a claim, declined supplemental jurisdiction over the state-law claims, and directed the Clerk to keep the matter open until a civil judgment is entered.