Purisima v. Mamdani
- Laura Swain
- 1:25-cv-09209
- U.S. District Court · Southern District of New York
- 4
In Purisima v. Mamdani, Judge Swain denied reconsideration of dismissal and denied fee-free appeal status after a bar-order violation.
Anton C. Purisima’s requests to reopen or change the dismissal were denied. The order also concerns defendants Zohran Mamdani and The “Others,” but it grants them no relief and orders no response from them.
What happened
Anton C. Purisima v. Zohran Mamdani; The “Others” began when the court dismissed Purisima’s complaint for failing to comply with a bar order from an earlier related proceeding. Judgment was entered the next day.
Purisima, who had no lawyer, filed an amended complaint and documents asking the court to reconsider the dismissal. One request concerned Defendant Mamdani’s full name in the caption; another sought responses from the defendants and asked the court to invalidate Mamdani’s election.
Judge Laura Taylor Swain denied the requests under the rules governing changes to a judgment and relief from a judgment. The court also denied fee-free appeal status, finding that an appeal would not be taken in good faith.
The detailed version
- Purisima v. Mamdani · No. 1:25-cv-09209
- Laura Swain
- Nov. 25, 2025
Background
Anton C. Purisima filed this action without a lawyer. On November 6, 2025, the court dismissed the complaint because Purisima had not complied with a bar order entered in an earlier related proceeding. The Clerk of Court entered judgment on November 7, 2025.
On November 7, Purisima filed an amended complaint, a document labeled “Notice of Motion,” and a supporting declaration. The court states that this motion sought to ensure that Defendant Zohran Mamdani’s full name appeared in the case caption. On November 10, Purisima filed another “Notice of Motion” and declaration. In those documents, he asked the defendants to respond to the complaint and sought to “invalidate the election of Mayor-Elect Mamdani.”
Motions Considered
The court liberally interpreted Purisima’s filings as three types of requests: a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e); a motion for reconsideration under Local Civil Rule 6.3; and a motion for relief from a judgment or order under Federal Rule of Civil Procedure 60(b). After reviewing the filings, the court denied the requests.
For Rule 59(e), the court held that Purisima had not shown that it overlooked controlling law or factual matters previously presented. The court noted that he had not sought permission to file the complaint, as required by the earlier bar order, and that nothing in his filings showed that this action differed from the pattern of nonmeritorious litigation that led to that order. The court therefore denied the Rule 59(e) motion.
The court explained that the standards under Rule 59(e) and Local Civil Rule 6.3 were the same. Because Purisima had not shown that the court overlooked controlling law or factual matters, the court denied the motion under Local Civil Rule 6.3 as well.
For Rule 60(b), which permits relief from a judgment for specified reasons such as mistake, newly discovered evidence, misconduct, or other extraordinary circumstances, the court found that Purisima had not shown that any of the first five listed grounds applied. The court denied relief under those grounds. The court also denied relief under Rule 60(b)(6), finding that Purisima had not demonstrated extraordinary circumstances warranting relief.
Disposition
The court denied Purisima’s motion for reconsideration, identified as ECF 6–10, and directed the Clerk of Court to terminate all motions in the action. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied fee-free appeal status for purposes of an appeal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.