Leonichev v. Alexander Robert Knoll

Background

Alexey Leonichev filed the complaint on June 10, 2025. He repeatedly objected to the assignment of Judge Cathy Seibel and Magistrate Judge Andrew Krause, arguing that he had not consented to the assignment and had demanded a jury trial. The court explained that assigning judges did not affect his right to a jury trial and that a judge was required to preside over the case. The court also explained that the change in the case number reflected the case’s location in White Plains rather than Manhattan.

Leonichev then repeatedly sought certificates of default against the defendants. The court explained that the defendants were not in default because their deadline to answer or move had been stayed under Judge Seibel’s Individual Rules of Practice after they filed a pre-motion letter. Leonichev continued submitting filings about the alleged default despite orders directing him to stop.

He also repeatedly challenged the authenticity of court orders and docket entries, the authority of defense counsel, and the court’s jurisdiction. He accused court personnel and others of criminal conduct and failed to appear at two pre-motion conferences. On July 31, 2025, the court ordered him not to make further submissions concerning these subjects and warned that violations could result in sanctions, including dismissal.

Prior sanctions and continued violations

After Leonichev failed to attend the rescheduled conference on September 3, 2025, the court ordered him to pay defense counsel $100 for reasonable expenses connected with the two conferences and imposed a $50 monetary penalty payable to the Clerk of Court for violating the July 31 order. On September 10, 2025, the court imposed additional monetary sanctions after finding that five later submissions violated the order. Two violations occurring after the warning of harsher sanctions resulted in penalties of $100 each.

Leonichev continued filing submissions challenging the same matters shortly after the September 10 order. The court treated those submissions as additional violations.

Legal standard and analysis

The court dismissed the case under Federal Rule of Civil Procedure 41(b), which permits dismissal when a plaintiff fails to comply with court orders. The court explained that dismissal with prejudice is a harsh sanction generally reserved for extreme situations involving willfulness, bad faith, or fault. It considered five factors: the duration of the noncompliance; whether the plaintiff was warned that noncompliance could result in dismissal; prejudice to the defendants; the balance between court administration and the plaintiff’s opportunity to be heard; and whether a less severe sanction had been adequately considered.

The court found that the duration of Leonichev’s noncompliance favored dismissal because it lasted through almost the entire case and involved approximately thirty-five submissions in two months. The warning factor also favored dismissal because he had been warned on July 31 and again on September 10 that continued violations could result in dismissal, yet he continued the same conduct.

The court found that the defendants had already been prejudiced because Leonichev’s failure to attend two conferences wasted their resources and delayed their proposed motion to dismiss. The court noted, however, that the defendants could still file that motion and that this factor did not strongly support dismissal.

The court also concluded that docket management favored dismissal. Although the case was only three months old and had not moved beyond the pleading stage, the docket had accumulated sixty-five entries because of Leonichev’s repetitive and irrelevant filings. The court further found that it had given him opportunities to raise his concerns, including at the two conferences he failed to attend.

Finally, the court found that lesser sanctions had not worked. Leonichev continued violating the court’s orders after monetary penalties were imposed. The court concluded that the case could not proceed while he refused to recognize the court’s authority and the authenticity of its orders.

Disposition

The court dismissed the case pursuant to Federal Rule of Civil Procedure 41(b). In light of Leonichev’s self-represented status and the court’s doubts about subject-matter jurisdiction, the dismissal was without prejudice. The Clerk of Court was directed to terminate pending motions and close the case. The court did not decide the merits of Leonichev’s claims.