Komatsu v. The City of New York

Background

Towaki Komatsu appeared without a lawyer and filed a 215-page complaint against dozens of defendants. The defendants included Silverstein Properties, Inc., the City of New York, police officers, employees of the New York City Human Resources Administration, City Council members, New York City Law Department employees, and other City employees. The complaint asserted 23 causes of action, including claims under the False Claims Act and the Racketeer Influenced and Corrupt Organizations Act, constitutional claims, wire-fraud claims, and state-law claims.

Komatsu had previously been subject to a prefiling injunction in this court. That injunction required him to obtain permission before filing any new action against the City of New York, city officials, and New York City police officers concerning alleged efforts to prevent him from attending public meetings with the Mayor. If permission was granted, the new complaint could not exceed 25 pages. The opinion also described a separate restriction concerning filings in cases to which Komatsu was not a party.

Court’s analysis

The court explained that complaints filed without advance payment of filing fees must be dismissed if they are frivolous or malicious, fail to state a legally sufficient claim, seek money from an immune defendant, or present claims over which the court lacks subject-matter jurisdiction. The court also noted that self-represented pleadings receive a generous reading but still must comply with the Federal Rules of Civil Procedure, including the requirement that a complaint provide a short and plain statement showing entitlement to relief.

The court applied Rules 18 and 20, which govern combining claims and parties. Rule 18 permits a plaintiff to join multiple claims against one defendant. Rule 20 permits joining defendants only when the claims arise from the same transaction, occurrence, or related series of events and share a common legal or factual question. The court held that Komatsu attempted to join many unrelated parties and claims in one action.

The court further held that Komatsu could not avoid the prefiling injunction by combining claims covered by that injunction with claims that might fall outside it. The court stated that publicly available records showed Komatsu had not sought permission before filing this action, even though the complaint included claims subject to the injunction.

Disposition

The court dismissed the action without prejudice for failure to comply with the prefiling injunction. The court stated that all filing restrictions remained in effect. It also certified that an appeal would not be taken in good faith and denied Komatsu permission to proceed without paying fees for purposes of an appeal. The Clerk of Court was directed to enter judgment.