Miller v. The City/State of New York

Background

Emily S. Miller brought this federal-question action without a lawyer against numerous identified and unidentified defendants. The defendants included an unidentified New York City Police Department officer, other identified police officers, Bellevue Hospital Center and security guards, an employee of New York Mental Hygiene Legal Services, her apartment building’s management company and the union representing its employees, the New York City Human Resources Administration, the New York City Department of Buildings, and what appeared to be the New York City Board of Education. The complaint alleged or described events occurring from the 1980s through August 2018, including arrests, physical injuries, involuntary hospitalization, injuries allegedly caused by hospital staff, state-court litigation, and disputes with various people and organizations.

The complaint was 432 pages including exhibits. After filing it, Miller submitted an additional 45-page collection of exhibits, which the court treated as a supplement. The court therefore described the pleadings as totaling 477 pages.

Legal standard

Because Miller had been allowed to proceed without prepaying the filing fee, the court was required to dismiss the complaint, or any part of it, if it was frivolous or malicious, failed to state a claim on which relief could be granted, or sought money from a defendant protected from that relief. The court also had to dismiss if it lacked subject-matter jurisdiction, meaning authority to hear the case.

The court said it must read filings by people without lawyers liberally and interpret them to raise the strongest claims the filings suggest. But those filings still must satisfy Rule 8(a) of the Federal Rules of Civil Procedure, which requires a short and plain statement showing that the plaintiff is entitled to relief. Rule 20 also limits when multiple defendants may be joined in one lawsuit: the claims must arise from the same transaction or occurrence, and there must be a common legal or factual question.

Court’s analysis

The court concluded that Miller did not provide the required short and plain statement. Instead, the pleadings described unrelated incidents, and the court said it could not sift through 477 pages to determine whether Miller had stated any claims. The court also concluded that the complaint did not suggest that common legal or factual questions connected all of the defendants.

The opinion contains an apparent typographical error in one sentence stating that the complaint “does comply with Rule 8”; the surrounding discussion and the court’s ruling state that the complaint failed to comply with Rule 8.

Ruling

The court dismissed the action for failure to state a claim on which relief may be granted. It dismissed the action without prejudice to Miller’s filing an amended complaint complying with Rules 8 and 20 within 30 days of the order. The court stated that the amended complaint must be short and plain, plausibly allege facts showing that Miller is entitled to relief, and include only defendants connected by common legal or factual questions.

The court also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal. The opinion directs the Clerk of Court to mail the order to Miller and note service on the docket.