Guzman v. New York City
- Laura Swain
- 1:25-cv-03338
- U.S. District Court · Southern District of New York
- 6
In Brian Guzman v. New York City, Judge Wood dismissed the case: Antrobus’s claims without prejudice under the three-strikes rule and Guzman’s for lack of jurisdiction.
Brian Guzman’s claims were dismissed without prejudice for lack of subject-matter jurisdiction, while Andre Antrobus’s claims were dismissed without prejudice under the prisoner three-strikes rule; both plaintiffs were affected by the dismissal.
What happened
Brian Guzman and Andre Antrobus, who were representing themselves and held at the George R. Vierno Center on Rikers Island, sued New York City and New York State. They described the sale of Manhattan Island as fraud and requested enormous damages and an injunction.
The court screened the complaint under laws requiring review of prisoner lawsuits against government entities. It denied Andre Antrobus’s request to proceed without paying filing fees because the three-strikes rule barred him from proceeding that way, and he did not allege imminent danger of serious physical injury. The court also concluded that Brian Guzman had not shown a personal injury caused by the defendants that a federal court could remedy.
The court dismissed Antrobus’s claims without prejudice and dismissed Guzman’s claims without prejudice for lack of subject-matter jurisdiction. It denied Guzman leave to amend, denied fee-free status for any appeal, and directed the Clerk to enter judgment dismissing the case. Judge Kimba M. Wood signed the order.
The detailed version
- Guzman v. New York City · No. 1:25-cv-03338
- Laura Swain
- Sept. 15, 2025
Background
Brian Guzman and Andre Antrobus, proceeding without lawyers, brought an action against New York City and New York State under the court’s federal-question jurisdiction. They asserted “fraud,” alleging that Manhattan Island was improperly sold and claiming injuries including lack of finances, mental anguish, and emotional distress. They sought punitive damages of “38,000,000,000,000.00,” “38 qaudrillion” dollars in compensatory damages, and an injunction.
The court had previously granted Guzman permission to proceed without prepaying filing fees. Antrobus did not sign the complaint, pay the filing fees, or seek permission to proceed without prepayment. The Prison Litigation Reform Act requires screening of qualifying prisoner complaints and permits dismissal of claims that are frivolous, malicious, fail to state a claim, seek relief from an immune defendant, or fall outside the court’s subject-matter jurisdiction.
Andre Antrobus
The court concluded that Antrobus was barred by the Prison Litigation Reform Act’s “three-strikes” provision from filing a new action without prepaying fees while incarcerated. The court also found that the complaint did not allege facts showing that Antrobus faced imminent danger of serious physical injury. Although courts ordinarily may allow a self-represented prisoner to correct filing defects, the court declined to do so here. It dismissed any claims filed on Antrobus’s behalf without prejudice. The conclusion separately states that the court denied Antrobus’s request to proceed without prepaying fees and that he remains barred from future fee-free filings while in custody unless he faces an imminent threat of serious physical injury.
Brian Guzman
The court held that Guzman lacked Article III standing, meaning he had not shown a personal injury fairly connected to the defendants’ conduct and likely to be remedied by the requested relief. The court said that Guzman’s allegations about the sale of Manhattan did not provide factual support showing that either defendant caused him an actual, redressable injury. Because a plaintiff without standing does not present a matter within the federal courts’ subject-matter jurisdiction, the court dismissed Guzman’s claims for lack of subject-matter jurisdiction.
Leave to Amend and Disposition
The court denied Guzman leave to amend because it concluded that he could not cure the defects in his complaint. It dismissed Guzman’s claims without prejudice under the cited jurisdictional provisions. The court certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. It directed the Clerk of Court to enter judgment dismissing the case. Judge Kimba M. Wood signed the order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.