Williams v. Office of Child Support
- Paul Engelmayer
- 1:21-cv-08235
- U.S. District Court · Southern District of New York
- 4
In Williams v. Office of Child Support, Judge Engelmayer partly granted and partly denied NYU Langone’s sanctions motion, barring related lawsuits without court permission but imposing no money penalty.
Sean Williams is subject to the filing restriction in the Southern District of New York concerning future lawsuits against NYU Langone about the alleged wage garnishment. NYU Langone benefits from that restriction; the court imposed no monetary sanctions.
What happened
Williams v. Office of Child Support concerns Sean Williams’s claim that NYU Langone Medical Center and the Office of Child Support unlawfully garnished his wages to satisfy child-support obligations ordered by Vermont. The court had already dismissed Williams’s claims as barred because they had been addressed and rejected in an earlier case.
NYU Langone later sought sanctions, including legal fees and an order requiring Williams to obtain permission before filing more related lawsuits. Williams did not respond, and no party objected to the magistrate judge’s recommendation that the motion be granted in part and denied in part.
Judge Engelmayer adopted the recommendation in full. The court barred Williams from filing related lawsuits against NYU Langone in that district without permission, but did not impose monetary sanctions; the case remains closed.
The detailed version
- Williams v. Office of Child Support · No. 1:21-cv-08235
- Paul Engelmayer
- June 13, 2023
Background
Sean Williams, representing himself, alleged that NYU Langone Medical Center and the Office of Child Support unlawfully garnished his wages to satisfy child-support obligations ordered by the State of Vermont. The court had previously dismissed Williams’s claims after concluding that they were barred by claim preclusion, a rule that generally prevents a party from relitigating claims already resolved in an earlier case.
After NYU Langone received what it described as a seemingly identical complaint, it moved for sanctions under Federal Rule of Civil Procedure 11. The motion sought double the costs and attorneys’ fees incurred in defending against Williams’s claims, as well as an injunction—an order restricting future conduct—that would prevent Williams from filing additional claims against NYU Langone without the court’s permission. Williams did not respond to the sanctions motion. The Office of Child Support had been served but did not respond or appear.
Report and Recommendation
The court referred NYU Langone’s sanctions motion to Magistrate Judge Robert W. Lehrburger. Judge Lehrburger recommended granting the motion in part and denying it in part, with the grant limited to barring Williams from filing lawsuits against NYU Langone concerning the alleged wage garnishment without first obtaining permission from the court. No party objected to the recommendation.
Because there were no objections, Judge Engelmayer reviewed the recommendation for clear error, meaning an obvious mistake apparent from the record. He found no such error and adopted the recommendation in its entirety.
Ruling
The court granted in part and denied in part NYU Langone’s motion for sanctions. It enjoined Williams from filing future lawsuits in the Southern District of New York against NYU Langone concerning the alleged garnishment of his wages unless he first sought leave of the court. The court did not impose monetary sanctions at that time, although it warned that a future frivolous action could result in additional sanctions, including monetary sanctions.
The court directed the Clerk to terminate the sanctions motion and stated that the case remains closed.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.