He v. United States of America

Background

Xuejie He filed a complaint against the United States, the States of New York and New Jersey, multiple judges, government agencies, and private and nonprofit entities. She described the case as seeking relief for discrimination against a victim of domestic violence. The court understood the main basis of her allegations to be dissatisfaction with how state and federal agencies handled and investigated her reports of rape and assault. She also alleged later harms involving medical treatment, housing, other assaults, court proceedings, and employment.

He requested relief including arrests, punishment of a person she identified as a perjurer, and hundreds of millions of dollars in unspecified damages.

Court’s Analysis

The court observed that most of the complaint was substantively identical to pleadings He had filed in a prior related proceeding in the District of New Jersey. That earlier proceeding had resulted in dismissals of the complaint, an amended complaint, and a second amended complaint, and the court noted that the United States Court of Appeals for the Third Circuit affirmed the district court’s orders.

The court applied claim preclusion, also called res judicata. This rule generally prevents a party from bringing claims that were already decided, or that could have been brought, in an earlier case involving the same opposing party or parties legally connected to that party. The court concluded that most of He’s claims arose from the same transactions and occurrences involved in the earlier proceeding. It therefore found that those claims were barred by claim preclusion or issue preclusion, which prevents relitigation of issues decided in an earlier case.

For allegations that were not otherwise barred, the court stated that it either lacked federal-question or diversity jurisdiction, or found the allegations frivolous or inadequately pleaded. The court also found that the complaint was so confused, vague, and difficult to understand that it did not comply with Rule 8 of the Federal Rules of Civil Procedure. In particular, the complaint did not adequately distinguish among defendants, identify the legal violations, establish the court’s jurisdiction, or provide enough facts to support possible claims.

The court separately discussed possible labor claims under New York law or the Fair Labor Standards Act, although those laws were not identified in the complaint. It could not determine which defendants He meant to sue, the relevant employment dates, the employers’ roles, He’s pay, or the damages sought. The court also stated that most, if not all, of those claims appeared time-barred under the applicable federal limitations periods.

Disposition

Judge Katherine Polk Failla dismissed the complaint without prejudice. The court granted He an opportunity to amend only claims that were not brought and could not have been brought in the prior related proceeding. The amended complaint was due June 20, 2023, and the court directed He to identify the claims and specific defendants, supporting facts, requested relief and the parties against whom it was sought, and the basis for federal jurisdiction. The court stated that if He did not file an amended complaint by that date, dismissal of the case would be with prejudice.