Clark v. Schroeder
- Vernon Broderick
- 1:20-cv-08000
- U.S. District Court · Southern District of New York
- 4
In Clark v. Schroeder, Judge Broderick dismissed Clark’s damages complaint with prejudice because Eleventh Amendment immunity barred it.
Sean A. Clark’s damages complaint against Mark Schroeder, sued in Schroeder’s official capacity as Commissioner of the New York State Department of Motor Vehicles, was dismissed with prejudice.
What happened
In Clark v. Schroeder, Sean A. Clark, representing himself, alleged that Mark Schroeder, the New York State Department of Motor Vehicles Commissioner, improperly disclosed Clark’s driver’s license number. Clark sought $600 quadrillion in damages and sued Schroeder in his official capacity.
The court concluded that the Eleventh Amendment generally bars damages claims against state officials sued in their official capacities. The court also noted that Clark did not allege facts showing Schroeder was personally responsible for the disclosure, and that Clark’s response to the court’s order did not correct these problems.
Judge Vernon S. Broderick dismissed the complaint on the court’s own initiative with prejudice, without allowing Clark to file an amended complaint. The Clerk was directed to enter judgment and close the case.
The detailed version
- Clark v. Schroeder · No. 1:20-cv-08000
- Vernon Broderick
- Nov. 5, 2020
Background
Sean A. Clark, appearing without a lawyer, sued Mark Schroeder, identified as the Commissioner of the New York State Department of Motor Vehicles. Clark alleged that his driver’s license number had been disclosed improperly. He sought "$600 quadrillion dollars" in damages. The complaint sought damages from Schroeder in his official capacity and did not allege that Schroeder was personally involved in the alleged disclosure.
The court had directed Clark to explain why the case should not be dismissed because of immunity under the Eleventh Amendment. Clark responded, but his response described the Commissioner’s official role and did not allege that Schroeder personally acted or failed to act in a way that violated Clark’s rights. The opinion also states that Clark had not served the complaint and summons on Schroeder.
Analysis
The court held that Eleventh Amendment immunity generally bars claims against state officials in their official capacities when the requested relief would bind the state or the state is the real party in interest. An exception can apply when a plaintiff seeks prospective injunctive relief—an order requiring future action—but Clark sought only monetary damages, so the exception did not apply.
The court therefore concluded that Clark’s damages claim against Schroeder in his official capacity was barred. It also observed that the complaint did not plead Schroeder’s personal responsibility for the alleged disclosure. The court determined that the claim lacked an arguable legal basis and that amendment would be futile because Clark had already been given an opportunity to address the immunity issue.
Disposition
The court dismissed the complaint on its own initiative with prejudice and without leave to replead. The Clerk was directed to enter judgment dismissing the complaint and close the case. Judge Vernon S. Broderick also directed the Clerk to mail a copy of the order to Clark.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.