Feliz v. Park
- Louis Stanton
- 1:20-cv-02014
- U.S. District Court · Southern District of New York
- 5
In Feliz v. Park, Judge Stanton dismissed Feliz’s complaint as barred by an earlier case and denied his counsel request as moot.
Alexander Feliz’s complaint was dismissed, and his request for appointment of counsel was denied as moot; the named defendants were not required to litigate the claims in this action.
What happened
In Feliz v. Park, Alexander Feliz, who was detained at the George R. Vierno Center, sued several defendants under a federal civil-rights law, claiming he was being illegally detained.
The court found that Feliz had already filed the same complaint against the same defendants in an earlier case, which had been dismissed on the merits. It therefore ruled that the claims were barred because they had already been decided or could have been raised earlier.
Judge Louis L. Stanton dismissed the complaint for failure to state a claim for relief and denied Feliz’s request for a lawyer as moot.
The detailed version
- Feliz v. Park · No. 1:20-cv-02014
- Louis Stanton
- June 25, 2020
Background
Alexander Feliz filed this action without a lawyer under 42 U.S.C. § 1983, alleging that the defendants were violating his constitutional rights. He claimed that he was being illegally detained under indictment number 00814/2017. The named defendants were Assistant District Attorney Jung Park, Judges Abraham Clott and Charles Solomon, Warden Tony Durante, the People of the State of New York, and the County of New York.
The court had allowed Feliz to proceed without paying the filing fee upfront. Because Feliz was a prisoner proceeding without prepayment of fees, the court screened his complaint under the Prison Litigation Reform Act. That law requires dismissal of a complaint that is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s jurisdiction.
Court’s analysis
The court found that Feliz had previously filed the same complaint against the same defendants in an earlier case in the Southern District of New York. That earlier action had been dismissed under the prisoner-screening statute. The court explained that a dismissal for failure to state a claim is treated as a final judgment on the merits for purposes of claim preclusion.
Claim preclusion, also called res judicata, generally prevents a party from bringing a new case against the same parties based on claims that were decided, or could have been raised, in an earlier case. The court concluded that the present claims arose from the same events as the earlier action and that the earlier action had been decided on the merits. It also noted that a court may raise claim preclusion on its own initiative. The opinion additionally states that Feliz filed an identical complaint in the United States District Court for the District of Columbia, but the ruling was based on the earlier Southern District of New York action.
Ruling
Judge Louis L. Stanton dismissed Feliz’s complaint for failure to state a claim upon which relief may be granted. The court also denied Feliz’s request for appointment of counsel as moot. The opinion did not reach the substance of whether Feliz’s detention violated the Constitution.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.