Soto v. Caputo

Background

T. King Connally-Bey filed the petition while claiming to act as the next friend of Dujuan Soto. A person acting as a “next friend” seeks to litigate for someone who cannot assert their own rights. The court had previously denied the petition because Connally-Bey’s submissions did not show that he had a significant relationship with Soto or that Soto was unable to assert his own rights. That earlier denial was stated to be without prejudice to any petition Soto might later file.

Connally-Bey then filed a letter arguing that access to New York State courts was being systematically and institutionally denied. He asked the court to treat the letter as an amendment seeking an order requiring a response in the state-court matter.

Motions and analysis

The court treated the filing as a motion under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment and under Local Civil Rule 6.3 for reconsideration. In the alternative, it treated the filing as a motion under Rule 60(b) for relief from the order or judgment.

The court denied the Rule 59(e) and Local Civil Rule 6.3 motion because Connally-Bey did not show that the court had overlooked controlling law or factual matters previously presented. The court also ruled that, to the extent he sought federal intervention in state-court proceedings, the Anti-Injunction Act prevented the requested relief. The court found that he had not shown that any of the Act’s three exceptions applied: congressional authorization, a need to aid the federal court’s jurisdiction, or a need to protect or enforce the federal court’s judgments.

The court denied the Rule 60(b) motion under clauses (1) through (5) because Connally-Bey had not shown that any of those grounds applied. It also denied relief under Rule 60(b)(6), finding that he had not demonstrated extraordinary circumstances warranting relief.

Disposition

The court denied Connally-Bey’s motion for reconsideration. It stated that the case was closed and that it would accept only documents directed to the United States Court of Appeals for the Second Circuit. The court warned that if Connally-Bey filed additional frivolous or meritless documents, it could require him to explain why he should not be barred from filing further documents in the action.

The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to appeal without paying the filing fee. Judge Laura Taylor Swain signed the order.