Joseph v. The State of New York

Background

Alfred Joseph, proceeding without a lawyer, sued the State of New York; Amsterdam, New York; the Netherlands; and the International Court of Justice. He invoked federal-question and diversity jurisdiction and sought to enforce what he called an “inalienable right to a better life experience.”

Joseph said his claims arose on October 8, 2008, September 7, 2009, and October 8, 2010, and identified the place of occurrence as “C-Span; Congress; ICJ,” with additional locations written in the margins. He described alleged events in Louisiana, including a post-conviction settlement that he said was taken from him, detention in Angie, Louisiana, an alleged attempted murder by Washington Parish Sheriff Tyler Self, and later alleged trauma, head injuries, loss of an eye, torture, and beatings. He also sought payment connected to United Nations governance, assets he said he won when the United States went into deficit to China, child tax credits, and alleged international court settlements.

Court’s Analysis

Because Joseph had been allowed to proceed without prepaying filing fees, the court was required to dismiss the complaint, or part of it, if it was frivolous, failed to state a claim, or sought money from an immune defendant. The court also had to dismiss claims over which it lacked authority to rule. Although courts read self-represented complaints liberally, the complaint still must provide enough facts to make a claim legally plausible.

The court concluded that there was no legal theory supporting Joseph’s claims. It held that the State of New York, the International Court of Justice, and the Netherlands were immune from suit. It found that Joseph alleged no facts about Amsterdam, New York. The court also concluded that, except for Joseph’s excessive-force claims, his factual assertions were not plausible.

For the claims involving injuries allegedly suffered in Louisiana more than a decade earlier, the court found that Joseph had not named any person who was personally involved in violating his rights. It dismissed those claims without prejudice to refiling them in an appropriate venue. It dismissed the remaining claims under 28 U.S.C. § 1915(e)(2)(B)(i) and (iii), provisions addressing frivolous claims and claims seeking relief from immune defendants.

Disposition

The court declined to allow Joseph to amend because it determined that amendment could not cure the complaint’s defects. It directed the clerk to enter judgment. It also certified that an appeal would not be taken in good faith and denied Joseph permission to proceed without prepaying fees for an appeal.