Araman v. Real Estate Board of New York

Background

Christine M. Araman, proceeding without a lawyer, sued the Real Estate Board of New York and numerous other defendants. She invoked federal-question jurisdiction and identified alleged antitrust violations, enterprise corruption, discrimination, medical malpractice, health-information violations, and violations of the standard of care. She sought damages, civil and criminal sanctions, protection orders, and reimbursement of legal and medical fees. She did not invoke diversity jurisdiction or identify the citizenship of the defendants.

On November 9, 2021, the court dismissed the action for lack of federal subject-matter jurisdiction and as frivolous. The court concluded that Araman’s allegations did not plausibly describe a legally viable federal claim and that her factual allegations were irrational or wholly incredible.

After that dismissal, Araman submitted letters asking that the case not be dismissed and requesting additional time. The court asked her to clarify whether she wanted reconsideration and, if so, to identify facts supporting federal-question or diversity jurisdiction. She later asked the court to treat her submission as a motion for reconsideration and eventually said she intended it to serve as a notice of appeal. She did not provide additional facts establishing either type of jurisdiction.

Arguments and legal standard

A motion for reconsideration asks a court to revisit an earlier decision. The court explained that such a motion generally requires an intervening change in controlling law, new evidence, or a need to correct a clear error or prevent serious injustice. It may not be used to present new facts or arguments or to repeat issues already decided.

Because Araman was representing herself, the court interpreted her filings to present the strongest arguments they reasonably suggested. The later submissions alleged, among other things, that prosecutors had brought repeated charges against her, individuals had made false statements about her, family members had initiated frivolous cases, and people had committed various criminal acts against her. She also sought protection orders and described her April 26 submission as a criminal complaint.

Court’s analysis

The court found that Araman’s submissions either repeated the allegations in her original pleading or made similarly incredible allegations. It concluded that she had not identified any factual or legal matter the court had overlooked that would change the November 9 decision. The court also adhered to its conclusion that the allegations did not plausibly describe a violation of federal law.

The court explained that the fact that alleged incidents occurred in New York could bear on personal jurisdiction or venue, but did not itself establish federal subject-matter jurisdiction. It also noted that Araman could not seek criminal sanctions or an order of protection from the federal court because a private person does not have a legally recognized interest in prosecuting someone else or obtaining such relief through a criminal prosecution. The court further noted that health-information law does not provide a private right to sue under the authority Araman invoked, and that her vague statement that some opposing parties were from different states did not alter the court’s conclusion.

Disposition

Judge Ronnie Abrams denied Araman’s motion for reconsideration. The court stated that its November 9 order had denied Araman all relief and closed the case, and directed the Clerk to enter judgment consistent with that order.

The court construed Araman’s November 19 submission as a notice of appeal and treated it as filed when the Clerk entered judgment. It stated that Araman may appeal under the federal appellate rules. The court also noted its prior certification that any appeal would not be taken in good faith and therefore denied permission to proceed without paying filing fees for purposes of the appeal.