Komatsu v. The City of New York

Background

Towaki Komatsu, representing himself, brought an action alleging that the defendants violated his rights. The case had been administratively closed after a judge imposed restrictions on Komatsu’s ability to file new civil actions against New York City officials concerning his exclusion from public meetings. A prior order determined that this action did not comply with those restrictions. Komatsu sought reconsideration and stated that this case instead concerned false-arrest and malicious-prosecution claims. The case was reopened so he could litigate those claims.

Order to Amend

The court granted Komatsu leave to file an amended complaint within 60 days. The amended complaint must assert facts supporting the false-arrest and malicious-prosecution claims and name only defendants whom Komatsu alleges were personally involved in those events. The court stated that facts concerning exclusion from public meetings would be stricken and that claims against defendants who were not personally involved in the alleged false arrest or malicious prosecution would be dismissed.

The court directed Komatsu to provide, for each defendant, a short and plain statement of the relevant facts, the defendant’s address, the defendant’s name and title when possible, what the defendant did or failed to do, the dates and locations of the events, how the conduct violated his rights, his injuries, and the relief requested. The amended complaint will completely replace, rather than supplement, the original complaint.

Recusal Request

Komatsu asked the judge to recuse himself based on the judge’s involvement in a prior related proceeding. The court denied the request. Applying the standard under 28 U.S.C. § 455(a), the court explained that recusal is required when a judge’s impartiality might reasonably be questioned, but that personal-bias claims ordinarily must arise from conduct outside the judicial proceedings. Judicial rulings alone, the court stated, almost never establish a valid basis for recusal.

The court found that Komatsu identified no facts showing deep-seated favoritism or antagonism that would make fair judgment impossible. It concluded that an objective observer would view Komatsu’s concern as dissatisfaction with the court’s rulings, which could be addressed through an appeal rather than recusal. Judge Louis L. Stanton therefore denied the motion seeking recusal.

Disposition and Next Steps

The court granted leave to file an amended complaint and denied the request for recusal. The amended complaint must be submitted to the court’s Pro Se Intake Unit within 60 days, labeled “Amended Complaint,” and identified with docket number 20-CV-10942 (LLS). No summons would issue at that time. If Komatsu failed to comply without showing good cause, the complaint would be dismissed for failure to state a claim. If he complied and stated a claim against the named defendants, the case would be reassigned under the clerk’s procedures.