Moody v. Clerk of Court

Background

Amari J. Moody proceeded without a lawyer and was granted permission to proceed without prepaying filing fees. He sued the Clerk of Court and District Executive of the United States District Court for the Southern District of New York in their official capacities, as well as the Office of the District Executive, ADA Coordination Unit, SDNY.

Moody brought claims under Title II of the Americans with Disabilities Act and the Fifth Amendment’s Due Process Clause. He sought an order requiring the defendants to provide accommodations in his pending actions in that court. He alleged that complications from surgery caused “neurological and vestibular impairments” that substantially limited his ability to participate in proceedings in person, by telephone, or by video. He alleged that only written, asynchronous participation was medically safe. He also alleged that he requested accommodations but was told that the requests involved case-management decisions reserved for judges.

The opinion notes that a chief judge had previously denied Moody’s request for a temporary restraining order and preliminary injunction. The court reviewed the complaint under the statute requiring dismissal of a complaint filed without prepaying fees if it is frivolous, malicious, fails to state a claim, or seeks relief from an immune defendant. The court also noted that it must dismiss claims over which it lacks subject-matter jurisdiction.

Americans with Disabilities Act claims

Title II of the Americans with Disabilities Act prohibits discrimination by a “public entity,” a term that covers state and local governments and related entities. The court held that Title II does not apply to the federal government or federal courts. Because Moody sued officials of the federal judiciary in their official capacities and a unit of a federal district court, the court dismissed his Americans with Disabilities Act claims for failure to state a claim.

The court also considered the Rehabilitation Act, even though Moody did not invoke it. The court explained that the Rehabilitation Act applies to programs or activities receiving federal funding assistance, but concluded that it does not apply to federal courts. The court therefore declined to grant Moody leave to amend the complaint to add Rehabilitation Act claims.

Due-process claims

The court held that sovereign immunity generally bars suits against the federal government, federal agencies, and federal officers sued in their official capacities unless immunity has been waived. Moody did not identify a waiver that applied to his claims against the federal officers and the federal judiciary unit. The court therefore concluded that sovereign immunity barred the claims.

The court also held that, even if Moody could identify a waiver allowing injunctive relief, his allegations did not state a procedural due-process claim. Such a claim requires a protected liberty or property interest and a deprivation of that interest without adequate process. The court reasoned that Moody could request accommodations from the judges presiding over his other actions and could seek reconsideration, provide supporting evidence, or obtain counsel. Because he had an opportunity to present his accommodation requests in those proceedings, the court concluded that he was not deprived of a protected interest without due process. The court further stated that the defendants did not have authority to override decisions made by the presiding judges.

Disposition

The court dismissed Moody’s Fifth Amendment claims based on sovereign immunity and failure to state a claim. It dismissed the complaint, declined to grant leave to amend because the defects could not be cured by amendment, and denied Moody’s pending motions because no relief was warranted. The court directed the Clerk of Court to terminate the pending motions and enter judgment dismissing the action.

The court also warned Moody that future non-meritorious motions filed after the action was closed would be denied summarily. The warning cited the requirement that all plaintiffs, including those proceeding without lawyers, make a good-faith determination that their factual and legal arguments are supported.