Renner v. New York State-People of the State of New York
- Laura Swain
- 1:21-cv-05850
- U.S. District Court · Southern District of New York
- 7
In Renner v. New York State-People of the State of New York, Judge Swain dismissed the amended complaint because it remained excessively long, unrelated, and legally deficient.
Yon Renee Woodson Awoonor Renner’s amended federal complaint was dismissed, and she was not granted another opportunity to amend. The order also denied permission to appeal without paying the filing fee.
What happened
In Renner v. New York State-People of the State of New York, Yon Renee Woodson Awoonor Renner filed an amended complaint alleging that hundreds of defendants violated her rights. The amended complaint was about 350 pages long and named approximately 222 defendants.
The court dismissed the amended complaint because it did not provide the short and plain statement required by Rule 8 and improperly combined unrelated claims against many defendants under Rule 20. The court also found that the amended complaint did not correct other problems identified in its earlier dismissal order, including claims barred by immunity and claims against parties who could not be sued under the theories asserted.
Judge Swain declined to allow another amendment because the defects could not be cured by further amendment. The court also terminated all pending motions and denied fee-free status for any appeal after certifying that an appeal would not be taken in good faith.
The detailed version
- Renner v. New York State-People of the State of New York · No. 1:21-cv-05850
- Laura Swain
- Jan. 3, 2022
Background
Yon Renee Woodson Awoonor Renner proceeded without a lawyer and with permission to file without paying the filing fee. She originally filed a 1,112-page complaint against 217 defendants concerning events from 2012 through 2020 in various New York locations. In an August 2, 2021 order, the court dismissed that complaint for violating Federal Rule of Civil Procedure 8, which requires a short and plain statement of the claim, and Rule 20, which limits the joining of unrelated claims and defendants. The court allowed Renner 30 days to replead and later granted two extensions.
Renner then filed a 350-page amended complaint naming approximately 222 defendants. As the court understood it, the amended complaint sought monetary damages based on allegations including separation from her home and sons, denial of due process, imprisonment, competency evaluations, sexual assault, false arrests, and actions by judicial officers. It asserted claims under several constitutional amendments, federal statutes, international instruments, and state law. Renner also filed documents titled Affidavit of Truth Hate Crime Complaint; the court noted that one later filing appeared to duplicate an earlier one. A proposed order seeking emergency injunctive relief had previously been denied.
Court’s reasoning
The court held that the amended complaint still violated Rule 8 because, although shorter than the original, it remained nearly impenetrable and did not present a short and plain statement showing entitlement to relief. It also held that the pleading violated Rule 20 because it did not show common legal or factual questions connecting the hundreds of claims against more than 220 defendants.
The court further stated that the amended complaint did not correct additional defects identified in the earlier order. Those defects included claims against judges barred by absolute judicial immunity; claims against prosecutors for acts within their official duties barred by prosecutorial immunity; claims against New York State and its agencies barred by the Eleventh Amendment; claims against municipal agencies or departments that lacked capacity to be sued under New York law; claims against municipalities without allegations that a municipal policy, custom, or practice caused a rights violation; requests by a private person for the arrest or prosecution of others under criminal law; and claims under 42 U.S.C. § 1983 against private parties who did not act under color of state law.
Disposition
The court dismissed the amended complaint for failing to remedy the deficiencies identified in the earlier dismissal order. It declined to grant another opportunity to amend, stating that the defects could not be cured by further amendment. The Clerk was directed to terminate all pending motions and mail Renner a copy of the order. The court certified that any appeal would not be taken in good faith and denied permission to proceed without paying the filing fee for purposes of an appeal.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.