Manchanda v. Matties

Background

Rahul Manchanda, an attorney representing himself, alleged that the defendants sent him a letter giving him seven days to pay $300,000 in cash or they would release allegedly illegally obtained information and audio or video recordings to the public. He claimed that the defendants intended to terrorize, blackmail, extort, threaten, humiliate, embarrass, and harass him and his family and business. He requested temporary and permanent orders barring the alleged conduct and sought $100 million in compensatory and punitive damages.

The Fourth Amended Complaint named individuals and entities, including Nicole Matties, Nicola Shapiro, the New York Federal Bureau of Investigation, the New York City Police Department, and others. Manchanda did not provide a copy of the alleged extortionate letter and did not explain many defendants’ identities or roles. He alleged that various defendants participated in an extortion, blackmail, hacking, or related operation.

Procedural History

The action was removed from New York state court to the Southern District of New York. On February 4, 2019, the court approved a stipulation voluntarily dismissing the action with prejudice as to the defendants covered by that stipulation. Manchanda later filed motions to reopen the case and to add attorneys as defendants. One defendant opposed reopening.

Court’s Analysis

The court denied the request to reopen the case as to the defendants covered by the earlier stipulation. Because that dismissal was with prejudice, the court found that Manchanda had offered no valid basis for reviving those claims.

The court also stated that, even without the earlier dismissal, it would dismiss the Fourth Amended Complaint. It concluded that the pleading did not adequately state any federal or state claim and described the allegation that the different agencies and individuals had conspired to extort Manchanda as fantastical. The court explained that it had authority to dismiss a frivolous complaint on its own motion. A frivolous claim, as the court used the term, is one based on clearly baseless factual allegations or an indisputably meritless legal theory.

The court further relied on the fact that five complaints had already been filed in the action, that the latest allegations were fantastical, and that Manchanda had a history of filing frivolous actions. It therefore dismissed the Fourth Amended Complaint without leave to amend, meaning it did not allow another amended complaint in this action. The court also noted that a lawyer representing himself ordinarily does not receive the special interpretive assistance given to an unrepresented nonlawyer.

Disposition

The court denied the motions to reopen and to add defendants. It dismissed the Fourth Amended Complaint without leave to amend, directed the Clerk to enter judgment and close the case, and certified that an appeal would not be taken in good faith. It consequently denied Manchanda permission to appeal without paying the filing fees.