Crumell v. The City of New York

Background

Damien Crumell, who was proceeding without a lawyer, invoked federal-question and diversity-of-citizenship jurisdiction. The complaint named the City of New York and numerous other individuals, agencies, organizations, and businesses. It alleged that his legal and constitutional rights had been violated and referred to defamation, emotional distress, harassment, stalking, sexual assault, intimidation, and other misconduct. The complaint directed the court to 131 additional pages containing lists of people, addresses, dates, events, and attached documents. It did not state the relief Crumell sought.

The court had previously granted Crumell permission to proceed without prepaying filing fees. When a person proceeds this way, the court must screen the complaint and dismiss it if it is frivolous or malicious, fails to state a legally sufficient claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction.

Court’s Analysis

The court held that the complaint did not comply with Rule 8 of the Federal Rules of Civil Procedure. Rule 8 requires a short and plain statement showing why the plaintiff is entitled to relief. The court found that Crumell’s lengthy allegations were often lists of people and places and did not provide enough factual detail to suggest a viable legal claim.

The court also held that the complaint did not comply with Rule 20. That rule generally permits multiple defendants to be joined in one lawsuit only when the claims arise from the same transaction or related series of events and involve a common question of law or fact. The court found no indication that the numerous defendants were connected by common legal or factual issues.

The court further explained that merely invoking federal-question jurisdiction is not enough; the complaint must identify a federal constitutional or statutory basis for the claims and allege facts supporting a federal cause of action. For diversity jurisdiction, the plaintiff must allege that the parties are citizens of different states and that the amount in dispute exceeds $75,000. The court noted that Crumell alleged that he resides in New York State, did not allege the defendants’ citizenship, and named the City of New York, which the court said is also a citizen of New York for this purpose.

Disposition

The court granted Crumell leave to file an amended complaint within 60 days of the order. The amended complaint must replace, rather than supplement, the original complaint; include a short and plain statement of the facts; explain what each defendant did, when and where it happened, and what injuries resulted; state the relief sought; and establish subject-matter jurisdiction. No summons would issue at that time.

The court did not dismiss the complaint immediately. It stated that the complaint would be dismissed for failure to state a claim if Crumell did not timely comply and could not show good cause. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.