Hyaciathe v. Social Security

Background

Raoul Hyaciathe filed the action without a lawyer and was allowed to proceed without paying the filing fee. His original complaint named “Social Security” as the defendant and alleged that his landlord charged him rent twice in one month. On May 16, 2022, the court gave him permission to file an amended complaint that complied with Rule 8 of the Federal Rules of Civil Procedure, which requires a short and plain statement showing entitlement to relief.

Hyaciathe’s amended complaint named Loni Fernandez and Community Access instead. He invoked diversity jurisdiction and indicated that he resides in New York, that Fernandez works at a Social Security office in New York, and that Fernandez works at Community Access in New York City. He repeated the allegation that his landlord made him pay rent twice in one month.

Court’s analysis

The court applied the screening requirements for a complaint filed without paying the filing fee. It explained that such a complaint must be dismissed if it is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction.

The court concluded that the amended complaint did not state facts showing that Fernandez or Community Access was responsible for violating Hyaciathe’s rights. The allegations suggested that Hyaciathe may have intended to sue Community Access as his landlord, but the court held that even this interpretation did not explain how charging rent twice in one month violated federal law.

The court also addressed diversity jurisdiction. It stated that the amended complaint did not show that the parties were citizens of different states or that the amount in controversy exceeded $75,000. The court further stated that, because the case concerned two rental payments, Hyaciathe could not show that the statutory amount was met.

Disposition

The court dismissed the amended complaint for failure to state a claim upon which relief may be granted. It granted Hyaciathe 30 days to file a second amended complaint and directed that any such complaint state facts suggesting that Community Access violated his rights under federal law. The court did not state that the dismissal was with or without prejudice.

The court certified that any appeal would not be taken in good faith and denied Hyaciathe permission to proceed without paying the filing fee for purposes of an appeal.