Komatsu v. The City of New York

Background

The court had previously dismissed Komatsu’s claims against Defendants Clark, Chhikara, and Brady based on prosecutorial immunity. It had also referred the case to a magistrate judge for general pretrial management and for proposed findings and recommendations on any motions that could dispose of claims. Komatsu, who was proceeding without a lawyer, then filed requests for Judge Caproni’s recusal, withdrawal of the referral, reconsideration of the earlier order, judicial notice of materials, leave to amend his complaint to add Judge Ramos, and other relief.

Rulings

The court denied the request for recusal. It applied the standard asking whether a reasonable, informed person would question the judge’s impartiality. Komatsu relied on Judge Caproni’s earlier involvement in an unrelated federal criminal matter involving him and statements about courthouse security officers. The court held that those statements did not provide a basis for recusal and arose in a judicial setting.

The court denied the motion to withdraw the reference to the magistrate judge. It explained that the referral for general pretrial management and recommendations on potentially dispositive motions was permitted by the federal statute governing magistrate judges, including when motions for injunctive relief might be involved.

The court denied the motion for reconsideration. It acknowledged that prosecutors are not protected by prosecutorial immunity from claims seeking properly prospective injunctive or declaratory relief. But it found that the relief Komatsu sought was not prospective because the Bronx criminal case at issue had ended. The court also stated that, even if the requested declaration were prospective, the Eleventh Amendment would bar a federal court from issuing a declaration that state prosecutors violated state law while carrying out their official duties.

The court denied Komatsu’s requests for judicial notice. It said that precedent did not need to be judicially noticed and that the remaining requests concerned matters unrelated to the earlier order under reconsideration. The court also denied Komatsu’s request to state that the earlier order had been dishonest and declined to reconsider its earlier certification that an appeal would not be taken in good faith. The court noted that Komatsu could still apply directly to the federal appeals court to proceed without paying filing fees.

The court denied leave to amend the complaint to add Judge Ramos as a defendant. It found the proposed claims meritless on their face and also held that judicial immunity blocked them because neither recognized exception to that immunity applied. The court noted that Komatsu had previously been allowed to amend his complaint to name unidentified defendants.

The court denied Komatsu’s request for a declaration that the Bronx Criminal Court protective order was void and for an order requiring the New York State court system to provide a transcript. It stated that federal courts could not second-guess state-court matters or order state courts to take particular actions. The court also denied Komatsu’s separate letter motion because its request concerning the New York City Police Department repeated relief sought in the amended complaint, while its requests concerning the Americans with Disabilities Act and other New York law were outside that complaint and unrelated to the litigation.

Disposition

The court denied the recusal request, the motion to withdraw the reference, the motion for reconsideration, the judicial-notice requests, the request to reconsider the appeal certification, the request for leave to amend to add Judge Ramos, the request for declaratory and transcript relief, and the letter motion. The order did not decide the merits of the requests for relief in Komatsu’s amended complaint, which the court said it would consider in the ordinary course.