SPENCER T. CRUMBSIE v. MUHAMMAD

Background

Spencer T. Crumbsie, who is detained at Westchester County Jail, represented himself and was allowed to proceed without paying the filing fee. He brought the action under 42 U.S.C. § 1983, alleging that Wali Muhammad, identified as his former defense attorney, and the Legal Aid Society of Westchester County violated his constitutional rights.

In the original complaint, Crumbsie alleged that during criminal proceedings in an unspecified court in Port Chester, New York, he requested a hearing under New York Criminal Procedure Law § 180.80, but Muhammad waived his right to a hearing without his knowledge. Crumbsie attempted to assert claims for “false representation” and “malicious prosecution.”

Earlier ruling and amended complaint

In an order dated June 3, 2026, the court dismissed Crumbsie’s Section 1983 claims because Muhammad and the Legal Aid Society were private parties who did not work for a state or government body. The court also concluded that it lacked diversity jurisdiction over the state-law claims because Crumbsie had not alleged his domicile or provided information about either defendant’s citizenship. Diversity jurisdiction is a form of federal jurisdiction that generally requires complete diversity of citizenship between the parties and an amount in controversy of more than $75,000.

The court gave Crumbsie permission to amend the state-law claims by alleging facts establishing diversity jurisdiction. He then submitted two letters, which the court treated as one amended complaint because he was representing himself. Crumbsie alleged that he had lived in Port Chester before his incarceration and referred generally to the defendants’ actions, but he did not allege the citizenship of Muhammad or the Legal Aid Society. The court also noted that he sought $50,000 in damages, below the $75,000 jurisdictional threshold.

Ruling

The court held that the amended complaint still did not establish diversity jurisdiction. It therefore dismissed the amended complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court also stated that it had not granted permission to assert new claims under federal-question jurisdiction and that the amended complaint did not suggest a viable federal claim.

Because Crumbsie had already been given an opportunity to amend and the amended complaint did not show that another amendment would cure the defects, the court declined to grant further permission to amend. Judge Louis L. Stanton dismissed the amended complaint without prejudice and directed the Clerk of Court to enter judgment dismissing the action without prejudice.