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S.D.N.Y.Procedural orderFiled Feb. 21, 2023

Manning v. United States Department of Justice

Judge
John Cronan
Docket
1:22-cv-01367
Court
U.S. District Court · Southern District of New York
Pages
1
Civil ProcedureMotion to Dismiss
In one sentence

In Manning v. United States Department of Justice, Judge Cronan dismissed Manning’s complaint for jurisdictional and pleading defects and denied amendment as futile.

Who this affects

Robert Steven Manning, the United States Department of Justice, and the United States Parole Commission. The complaint was dismissed, the motion to amend was denied, and the case was closed; the judgment states that a separate detention challenge may be brought in the proper jurisdiction.

What happened

In Manning v. United States Department of Justice, Robert Steven Manning sued the United States Department of Justice and the United States Parole Commission. The judgment does not describe the underlying allegations.

The court dismissed the complaint because it lacked subject-matter jurisdiction, meaning the court lacked legal authority to hear it, and alternatively because it failed to state a legal claim. The court also denied Manning’s motion to amend the complaint as futile. The judgment’s text is unclear where it describes the proposed amendment and the defect it was supposed to address.

Judge Cronan’s judgment states that the dismissal was without prejudice to any petition Manning might bring seeking a court order challenging his detention in the proper jurisdiction. The case was closed.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Manning v. United States Department of Justice · No. 1:22-cv-01367
Judge
John Cronan
Date
Feb. 21, 2023

Background

Robert Steven Manning was the plaintiff. The defendants were the United States Department of Justice and the United States Parole Commission. The judgment does not state the factual allegations or the specific relief Manning requested.

Rulings

The judgment incorporates the reasons given in the Court’s February 17, 2023 Order. It states that the Court dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). Subject-matter jurisdiction is the court’s legal authority to hear a dispute. Alternatively, the Court dismissed the complaint under Rule 12(b)(6) for failure to state a claim, meaning the complaint did not present a legally sufficient claim for relief.

The Court also denied Manning’s motion to amend the complaint as futile. The judgment says Manning sought to add a defendant, but the text identifying that proposed defendant is incomplete; it refers to the Federal Correctional Institution Phoenix. The judgment contains a garbled sentence about whether the proposed amendment would address the defect in the complaint, so the precise reasoning on that point is unclear.

Disposition and Effect

The judgment states that the dismissal is without prejudice to any petition for a writ of habeas corpus that Manning may seek in the proper jurisdiction. In plain English, the judgment leaves open a possible separate petition challenging his detention in the appropriate court. It also states that the case is closed. Judge John Cronan is identified as the judge in the case information supplied with the opinion.

Classification

This is a procedural order because the complaint was dismissed under Rules 12(b)(1) and 12(b)(6), without the court deciding the underlying legal dispute on its merits.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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