Singleton v. City of New York Comptroller Office

Background

Aaron Singleton, who was incarcerated on Rikers Island, filed this case without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims for violations of constitutional rights by state actors. He alleged that settlement money owed to him by the New York City Comptroller’s Office was transferred to child-support authorities through a lien without his consent, violating the Fifth Amendment.

The documents attached to the complaint showed that Singleton was required to pay $75.79 per week in child support and owed $20,819.76 in unpaid support as of May 29, 2020. He had filed a claim against New York City that settled for $9,000 on May 7, 2020. After attorney’s fees, $5,567 was to be paid directly to the Support Collection Unit because a child-support lien had been filed against him.

Singleton named the New York City Comptroller’s Office, “New York State Child Support,” and the “New York State Department of Social Services.” The court said the attached documents suggested that he might have been referring to the New York State Division of Child Support Services, the New York City Child Support Enforcement Unit, the Support Collection Unit, or all three.

Reasons for dismissal

The court screened the complaint under statutes requiring dismissal of a case filed without prepayment of fees if it is frivolous, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court also said it must read filings by people without lawyers broadly and interpret them to present the strongest claims they suggest.

State-agency immunity. The court held that the § 1983 claims against the New York State Department of Social Service were barred by the Eleventh Amendment. That doctrine generally protects states and state agencies from lawsuits in federal court. The court stated that New York had not waived that protection and that Congress had not removed it through § 1983. Those claims were dismissed.

State-court judgment review. The court held that the claims against the Comptroller’s Office and “New York State Child Support,” which the court said presumably referred to the New York City Support Collection Unit, were barred by the Rooker-Feldman doctrine. That doctrine prevents federal district courts from reviewing or rejecting final state-court judgments. The court explained that it applies when a federal plaintiff lost in state court, was injured by the state-court judgment, asks the federal district court to reject that judgment, and filed the federal case afterward.

The court applied that rule because the Support Collection Unit was acting to collect money under a state-court child-support order, and the Comptroller’s Office was releasing the settlement money under that order. The court stated that challenges to the validity or enforcement of child-support orders, including enforcement through garnishment, are barred by this doctrine. It therefore did not decide whether the garnishment violated the Fifth Amendment.

Leave to amend and state-law claims

The court denied Singleton permission to amend the complaint because it concluded that the defects could not be cured by amendment. After dismissing the federal claims, the court also declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—over any state-law claims Singleton might have been asserting.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B), citing the statutory grounds listed in the order. The order also directed the Clerk of Court to mail Singleton a copy and record service on the docket.