Craft v. New York State Supreme Court

Background

Christopher D. Craft, Sr., appearing without a lawyer, sued the New York State Supreme Court, Dutchess County, and Justice Christie L. D’Alessio. Craft alleged that, on June 21, 2022, Justice D’Alessio held a hearing concerning an order of protection. Craft alleged that New York State Trooper Brian McGee had a handwritten application for an order of protection and a “falsified search warrant application.” Craft further alleged that Justice D’Alessio denied his requests to question Trooper McGee and obtain body-camera footage, which Craft claimed violated procedural due process.

Craft alleged that Justice D’Alessio granted the order of protection, which, among other things, barred Craft from owning or purchasing a gun for one year. Craft described himself as an avid outdoorsman who hunts, fishes, and traps animals to provide for his family. He sought damages and asked that the defendants be criminally prosecuted.

Screening Standard

Because Craft was allowed to proceed without prepaying filing fees, the court was required to screen the complaint under 28 U.S.C. § 1915. The court had to dismiss the complaint, or any part of it, if it was frivolous or malicious, failed to state a claim for relief, or sought money from a defendant legally immune from such relief. The court also had to dismiss claims over which it lacked subject-matter jurisdiction. Although courts read filings by people without lawyers generously, those filings must still provide enough facts to make a legally plausible claim.

Reasons for Dismissal

Eleventh Amendment immunity. The court held that the New York State Supreme Court, Dutchess County, is part of the New York State Unified Court System and is therefore an arm of the state. The Eleventh Amendment generally prevents states and state entities from being sued for damages in federal court unless the state has waived that protection or Congress has removed it. The court found that New York had not waived its immunity and that Congress had not removed it through 42 U.S.C. § 1983. It therefore dismissed Craft’s § 1983 claims against the state court based on Eleventh Amendment immunity.

Judicial immunity. The court held that Justice D’Alessio was absolutely immune from damages claims for actions taken within his judicial responsibilities. The allegations concerned actions related to a case before him, and Craft did not allege facts showing that the judge acted outside his judicial role or jurisdiction. The court therefore dismissed the claims against Justice D’Alessio because they sought money from a defendant immune from that relief.

The court separately ruled that Craft could not prosecute criminal charges against Justice D’Alessio. The decision to bring criminal charges belongs to prosecutors, not private citizens. The court therefore dismissed all of Craft’s claims against Justice D’Alessio.

Challenge to the state-court judgment. The court explained that federal district courts generally cannot review or overturn state-court judgments. It held that, to the extent Craft sought to overturn or vacate the order of protection, he was asking the federal court to review and reject a state-court judgment after losing in state court. The court dismissed that aspect of the case under the Rooker-Feldman doctrine, which bars federal district courts from acting as appellate courts over state-court judgments. The court stated that any review of Justice D’Alessio’s decision, if available, would have to occur within the state court system.

Disposition

The court dismissed Craft’s complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) and (iii). It declined to grant leave to amend because the defects could not be cured by amendment. The court certified that an appeal would not be taken in good faith and denied Craft permission to appeal without prepaying fees. Judgment was ordered to issue.