Manko v. Lenox Hill Hospital

Background

Nella Manko proceeded without a lawyer and paid the filing fee. She sued 39 defendants, including the New York State Unified Court System, the New York State Court of Appeals, the New York Supreme Court, Appellate Division, First and Second Departments, the City of New York, the New York City Transit Authority, Lenox Hill Hospital, and numerous private defendants, including doctors, lawyers, and law firms.

Manko asked the federal court to reverse decisions from New York state courts in several cases. She cited excusable default, newly discovered evidence, fraud, and claims that the state-court orders were arbitrary, capricious, or unsupported by substantial evidence. The opinion also describes Manko's prior state and federal litigation involving some of the defendants and prior orders restricting her ability to file new cases without permission when she did not pay filing fees. Because she paid the filing fee in this action, that restriction did not apply here.

Reasons for dismissal

The court first applied the Rooker-Feldman doctrine. That doctrine generally prevents federal district courts from reviewing final state-court judgments. The court found that Manko had lost in state court, alleged injuries caused by state-court judgments, asked the federal court to reverse those judgments, and filed the federal action after the state-court decisions. It therefore dismissed the claims on that basis, including the claims against the New York City Transit Authority that appeared to arise from the state-court judgments.

The court also dismissed Manko's claims under 42 U.S.C. § 1983 against private parties. A claim under that statute requires facts showing that the defendant acted under government authority. The court held that the private defendants, including the doctors, lawyers, and law firms, were not generally liable under § 1983 on the allegations presented.

The court dismissed the § 1983 claims against the State of New York, the New York State Unified Court System, the New York State Court of Appeals, and the New York Supreme Court, Appellate Division, First and Second Departments, because the Eleventh Amendment generally protects states and state instrumentalities from suit in federal court. The court stated that New York had not waived that immunity and that Congress had not removed it through § 1983.

The court separately dismissed the claims against the City of New York because Manko did not allege facts showing that a city policy, custom, or practice caused a violation of her constitutional rights. The court also declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, because it had dismissed the federal claims. The opinion additionally states that Manko did not establish federal diversity jurisdiction over any state-law claims.

Disposition

The court dismissed the complaint under the Rooker-Feldman doctrine, under Eleventh Amendment immunity, and for failure to state a claim on which relief may be granted. It declined to exercise supplemental jurisdiction over any state-law claims Manko may have been asserting. It denied leave to amend because the defects could not be cured by amendment.

The court warned that continued repetitive or frivolous litigation could result in an order barring Manko from filing new actions in the Southern District of New York, even if she paid the filing fees. It certified that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees. The order was signed by Chief United States District Judge Laura Taylor Swain.