Jones v. Williams

Background

Jonathan A. Jones filed the action without a lawyer and was allowed to proceed without paying the filing fee in advance. His complaint invoked federal-question jurisdiction and named Jay Shaqwan Williams and New York State as defendants. The complaint contained difficult-to-read allegations concerning events in Staten Island on October 9, 2016, as well as other alleged injuries. Jones requested more than $300 million in damages.

The court noted that Jones had filed a substantially similar lawsuit in a prior related proceeding, No. 22-CV-4205 (S.D.N.Y.). In that earlier round, the court dismissed the claims against Williams for failure to state a claim and allowed Jones to amend claims against a city defendant. Jones did not file an amended complaint, and that action was dismissed.

Claims Against Williams

The court treated Jones’s allegations against Williams as claims under 42 U.S.C. § 1983, a federal law that allows lawsuits for certain violations of constitutional rights by people acting under state authority. The court held that the complaint did not allege facts showing that Williams personally harmed Jones, acted under state authority, or engaged in any specific conduct that explained why he was named as a defendant. The court therefore dismissed the claims against Williams for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii).

Claims Against New York State

The court found that the complaint did not suggest involvement by any New York State actor in the alleged violation of Jones’s rights. The court also held that, even if such involvement had been alleged, New York State is protected from this type of § 1983 lawsuit in federal court by immunity under the Eleventh Amendment. The court stated that New York had not waived that immunity and that Congress had not removed it through § 1983. The court dismissed any § 1983 claim against New York State under 28 U.S.C. § 1915(e)(2)(B)(iii).

Leave to Amend and Disposition

The court denied Jones leave to file an amended complaint. It explained that Jones had already received an opportunity to amend a substantially similar complaint in the prior related proceeding, but instead filed this new action with the same defects. The court concluded that allowing another amendment would be futile.

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii)-(iii). It certified that an appeal would not be taken in good faith and denied Jones permission to proceed without paying fees for an appeal. The court directed the Clerk to enter judgment.