Rajapakse v. Shaw
- Valerie Caproni
- 1:20-cv-10473
- U.S. District Court · Southern District of New York
- 9
In Rajapakse v. Shaw, Judge Stanton found the complaint incomplete and granted 60 days to amend it with facts supporting the claims and venue.
Samantha D. Rajapakse was given an opportunity to amend her complaint; Seyfarth Shaw, Robert Szyba, and Carla Laingan were the named defendants, but the court did not reach the merits of the allegations.
What happened
In Rajapakse v. Shaw, Samantha D. Rajapakse, representing herself, alleged that Seyfarth Shaw, Robert Szyba, and Carla Laingan violated her Fourteenth Amendment rights. She provided no factual allegations beyond listing alleged injuries involving a security background check, credit, and emotional and physical harm.
The court found that the complaint did not provide the short and plain statement required by federal rules and appeared to be incomplete. It also directed Rajapakse to provide facts showing that venue—the proper federal court location—was appropriate in the Southern District of New York.
Judge Louis L. Stanton granted Rajapakse 60 days to file an amended complaint, which would replace the original complaint. No summons would issue at that time, and the order warned that failure to amend without good cause would lead to dismissal for failure to state a claim.
The detailed version
- Rajapakse v. Shaw · No. 1:20-cv-10473
- Valerie Caproni
- Jan. 5, 2021
Background
Samantha D. Rajapakse, appearing without a lawyer, invoked federal-question jurisdiction and alleged that Seyfarth Shaw, Robert Szyba, and Carla Laingan violated her rights under the Fourteenth Amendment. The court had previously granted her permission to proceed without paying filing fees.
Rajapakse used the court’s general complaint form. She identified herself as a resident of Chattanooga, Tennessee; described Seyfarth Shaw as a law firm with offices in New York, Chicago, and Massachusetts; and listed addresses for the individual defendants in New York and Massachusetts. She said that her claims arose from events in New York, Boston, and Tennessee between June 2020 and December 3, 2020.
In the form’s facts section, Rajapakse wrote, “Please see attach complaint,” but no complaint was attached, and the submission contained no other factual allegations. She listed alleged injuries including denial of a security background check, fear of using credit, denial of credit, and emotional and physical damages. She requested $1 million in physical damages.
Court’s Analysis
The court explained that it must screen a complaint filed without prepaying fees and dismiss it if it is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. It also explained that pleadings by people without lawyers are read liberally, but they still must provide enough factual detail to make a claim plausible and satisfy the requirement for a short and plain statement showing entitlement to relief.
The court held that Rajapakse’s submission did not comply with that requirement because it alleged no facts and appeared incomplete. The court therefore could not determine whether she had stated a claim.
The court also addressed venue, meaning whether this was the proper federal district in which to bring the case. Because Rajapakse identified events in several places and gave addresses connected to New York, Massachusetts, and Illinois, the court directed her to allege facts showing that venue was proper in the Southern District of New York.
Order
The court granted Rajapakse leave to file an amended complaint within 60 days. The amended complaint had to provide a short and plain statement of the relevant facts supporting each claim against each defendant, addresses for the defendants, and information about the people involved, the relevant events, dates, locations, alleged rights violations, injuries, and requested relief.
The amended complaint would completely replace, rather than supplement, the original complaint. The court directed Rajapakse to submit it to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 20-CV-10473 (LLS). No summons would issue at that time. The order stated that if she did not comply within the permitted period and could not show good cause, the complaint would be dismissed for failure to state a claim. The order was signed by Louis L. Stanton, United States District Judge.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.