Barton v. Clark

Background

Michael Alexander Barton filed a lawsuit invoking federal-question jurisdiction. The opinion states that Barton was detained at the Eric M. Taylor Center on Rikers Island and represented himself. The defendants were identified as Bronx District Attorney Darcel Clark, the New York State Police, New York State Attorney General Letitia James, the Bronx County Clerk, Bronx Supreme Court Justice George Villegas, and the “New York State Bronx Supreme Criminal Court.”

Barton’s complaint listed alleged violations including unlawful arrest, illegal restraint, excessive bail, cruel and unusual punishment, denial of a speedy trial, freedom of speech, due process, defamation, trademark infringement, theft of property, and unlawful incarceration. The complaint also appeared to assert claims on behalf of Divine Freedom Ministries. Its attachments relied on theories associated with the “sovereign citizen” and “redemptionist” movements, including purported private settlements, Uniform Commercial Code liens, and monetary demands.

Screening standard

The court screened the complaint under the Prison Litigation Reform Act, which requires dismissal of a prisoner’s complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant immune from such relief. The court also considered whether it had subject-matter jurisdiction. Although courts read complaints filed by people without lawyers liberally, the complaint still must provide enough facts to make a claim legally plausible.

Claims for Divine Freedom Ministries

The court dismissed any claims Barton attempted to bring for Divine Freedom Ministries because a nonlawyer may represent only himself. This dismissal was expressly without prejudice to Divine Freedom Ministries bringing claims through licensed counsel.

Constitutional claims

The court treated Barton’s federal constitutional claims as claims under 42 U.S.C. § 1983, a statute allowing suits for violations of federal rights by persons acting under state authority.

The claims against Darcel Clark were dismissed because the allegations appeared to concern actions within the scope of her official duties and connected to the conduct of a criminal trial. Prosecutors have absolute immunity from damages claims for such conduct.

The claims against Justice George Villegas and the Bronx County Clerk were also dismissed. The court found that the allegations against Justice Villegas concerned acts related to cases before him, for which judges generally have absolute immunity. The court understood the claims against the Bronx County Clerk to concern functions related to Barton’s criminal proceedings, giving the clerk similar, or quasi-judicial, immunity. The complaint also did not allege facts showing how the clerk was involved.

The § 1983 claims against the New York State Police and the New York State Supreme Court, Bronx County, were dismissed under the Eleventh Amendment, which generally protects states and state instrumentalities from suit in federal court. The court also stated that the Eleventh Amendment barred damages claims against Letitia James in her official capacity. The opinion noted an exception for certain ongoing violations where prospective relief is sought, but found that Barton had not alleged facts fitting that exception.

Redemptionist and sovereign-citizen theories

The court concluded that many of the complaint’s assertions appeared to rely on redemptionist or sovereign-citizen theories. It stated that federal courts have consistently rejected those theories as legally frivolous. The claims based on those theories were dismissed as legally frivolous under the prisoner-screening statute.

State-law claims and amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over any state-law claims Barton may have asserted.

The court denied leave to amend. Although people representing themselves are generally given an opportunity to amend when a valid claim might be stated, the court found that Barton’s claims were legally frivolous and that the defects could not be cured by amendment.

Disposition

The complaint was dismissed for failure to state a claim for relief, seeking monetary relief from an immune defendant, and being legally frivolous. Claims brought on behalf of Divine Freedom Ministries were dismissed without prejudice. The court declined supplemental jurisdiction over any state-law claims, directed the clerk to enter judgment, and certified that any appeal would not be taken in good faith, denying permission to proceed without paying appellate fees.