Stevenson v. De Blasio

Background

Eric Stevenson filed the action without a lawyer under 42 U.S.C. § 1983 and the Voting Rights Act. He sued Mayor Bill De Blasio, the Speaker of the New York City Council, the City Council of New York, and the Commissioner of the Board of Elections of the City of New York. Stevenson alleged that the defendants violated his federal constitutional rights by removing his name from the ballot for an unspecified election and office. He sought declaratory and injunctive relief, including restoration of his name to the ballot and access to public campaign funds, as well as damages.

Stevenson challenged New York City Charter § 1139, also called Local Law No. 15. The provision disqualifies a person from being elected to or holding certain city offices after conviction of specified felonies, including certain federal offenses. The opinion states that Stevenson had been convicted in federal court of offenses including bribery, conspiracy, and extortion under color of official right, and that his conviction and sentence were affirmed on appeal.

In April 2021, another primary candidate asked a New York state trial court to invalidate Stevenson’s candidacy under Section 1139. Stevenson opposed that request and asserted a counterclaim challenging the law’s constitutionality. On May 5, 2021, the state court invalidated his candidacy, ordered his name removed from the ballot, and dismissed his counterclaim. The state appellate court affirmed on May 12, 2021, and New York’s highest court denied leave to appeal on May 18, 2021.

Court’s analysis

The court had granted Stevenson permission to proceed without paying the filing fee. It explained that it must dismiss such a complaint, or part of it, if the claims are legally frivolous, fail to state a claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also noted that pleadings filed by people without lawyers are read generously, but still must provide enough facts to make a plausible claim for relief.

The court focused on the Rooker-Feldman doctrine. This doctrine generally prevents federal district courts from reviewing and overturning final judgments entered by state courts. The court identified four requirements for applying the doctrine: the federal plaintiff lost in state court; the claimed injury was caused by the state-court judgment; the plaintiff asks the federal district court to review and reject that judgment; and the state-court judgment came before the federal case began.

The court said Stevenson appeared to satisfy those requirements because he sought an order revalidating his candidacy and returning his name to the ballot after the state court had invalidated his candidacy. The court noted that the state decision had already been affirmed on appeal and that further review had been denied before Stevenson filed this federal action. The opinion also stated that the available appellate decision did not clearly identify all grounds on which the state trial court had dismissed Stevenson’s constitutional counterclaim.

Order and possible disposition

The court directed Stevenson to show cause—meaning to explain why the court should not take the proposed action—by noon on June 16, 2021. He was directed to submit the required declaration and attach the state trial court’s May 5 decision, or explain why he could not provide it.

This order did not itself dismiss the action. It stated that, if Stevenson failed to comply or failed to show cause, the court would dismiss his declaratory and injunctive claims for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine. It also stated that the court would dismiss his damages claims without prejudice because of a failure to comply with the order. The court further certified that an appeal would not be taken in good faith and denied fee-waiver status for an appeal.

The opinion is signed by Chief United States District Judge Laura Taylor Swain.