Young v. James

Background

Huguette Nicole Young, proceeding without a lawyer, sued Letitia James in her official capacity as attorney general of New York. Young sought to invalidate and prevent enforcement of Executive Order No. 202.17, which the opinion describes as New York’s mask mandate. She claimed that the order violated her First Amendment rights. Young alleged that she had visited New York and was required to wear a mask in a Walmart store, and that she might later visit New York because of her employment as a long-haul truck driver.

James moved to dismiss the action. A magistrate judge recommended dismissing the case for lack of subject-matter jurisdiction, or, alternatively, dismissing Young’s claims on the merits if the court found that Young had standing.

Court’s Analysis

No party objected to the magistrate judge’s report and recommendation. The district court therefore reviewed the report for clear error, meaning an obvious mistake on the face of the record. Judge Engelmayer found no such error and adopted the recommendation that the complaint be dismissed for lack of subject-matter jurisdiction.

Because the court dismissed the case on that jurisdictional ground, it did not address the merits of Young’s First Amendment claims or the alternative merits analysis in the report. The opinion also states that the parties’ failure to object within the stated period waived objections and precluded appellate review.

Disposition

The court granted James’s motion and dismissed the action without prejudice for lack of subject-matter jurisdiction. The clerk was directed to terminate the pending motion and close the case.