Smith v. Stack

Background

Jahmal Ahmed Smith, appearing without a lawyer, filed an action invoking diversity jurisdiction and alleging federal and state-law claims. He sued Eileen Stack, identified as Deputy Commissioner of the New York State Office of Temporary and Disability Assistance overseeing its Division of Child Support Services, and Melvin C. Dalere, identified as a Support Magistrate of the New York Family Court, Bronx County.

Smith alleged that New York family courts had engaged in misconduct and that the defendants had used fraudulent child-support orders and wage-withholding documents. He alleged that a September 30, 2022 withholding notice caused his employer to deduct money from his wages to pay child-support arrears without providing him a court order. The complaint sought the return of unspecified amounts and $1,000,000 in damages. The attached records stated that he had approximately $30,337.64 in child-support arrears and that a June 2022 Family Court order ended prospective support payments effective April 21, 2022, without eliminating existing arrears.

The court had previously allowed Smith to proceed without paying filing fees. It reviewed the complaint under the statute requiring dismissal of a fee-free complaint that is frivolous, malicious, fails to state a claim, or seeks money from an immune defendant, and also considered whether it had subject-matter jurisdiction.

The Court’s Rulings

- Claims brought for other people: The court dismissed without prejudice any claims Smith asserted for family members or anyone else because a person who is not an attorney cannot represent other people in federal court. - Requests for criminal prosecution: To the extent Smith sought criminal prosecution of the defendants or others, the court dismissed those claims for lack of subject-matter jurisdiction. A private person cannot direct prosecutors to bring criminal charges. - Bill of attainder: The court dismissed the claim that wage withholding for child-support arrears was a bill of attainder for failure to state a claim. Smith identified no law directed at him individually; the alleged withholding appeared to result from prior Family Court proceedings and orders. - Claims against Support Magistrate Dalere: The court dismissed Smith’s claims for damages under 42 U.S.C. § 1983 against Dalere because judicial officers are generally immune from damages claims for acts performed as part of their judicial responsibilities. The court also concluded that the allegations did not show that Dalere acted outside his judicial role or without jurisdiction. The court stated that the statutory limits on injunctive relief against judicial officers also precluded Smith’s request for injunctive relief against Dalere because state-court review was available. - Ongoing Family Court proceedings: To the extent Smith asked the federal court to intervene in pending New York Family Court child-support proceedings, the court dismissed those claims under the Younger abstention doctrine. That doctrine generally prevents a federal court from interfering with certain ongoing state proceedings, and Smith had not alleged the required bad faith, harassment, or serious and immediate irreparable injury. - Challenges to completed state-court decisions: To the extent Smith asked the federal court to overturn final Family Court decisions, the court dismissed those claims for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine. That doctrine prevents a federal district court from functioning as an appeals court for state-court judgments. - Procedural due process: The court understood Smith to allege that wage withholding deprived him of property without a hearing. It dismissed those § 1983 claims for failure to state a claim because New York law provides administrative and judicial procedures for challenging errors in child-support withholding, and Smith did not allege that he used those procedures or that they were inadequate. - Title IV-D claims: The court dismissed Smith’s claims based on Title IV-D of the Social Security Act for failure to state a claim. The court held that Title IV-D does not give individuals a federal right to require substantial compliance by a state child-support agency and does not create a private right to sue under § 1983. - Remaining state-law claims: The court dismissed any remaining state-law claims brought under diversity jurisdiction for lack of subject-matter jurisdiction because Smith did not provide Support Magistrate Dalere’s state citizenship and did not allege facts showing that the amount in controversy exceeded $75,000. The court also declined to exercise supplemental jurisdiction over any remaining state-law claims after dismissing the federal claims. - Amendment and final disposition: The court declined to give Smith permission to amend because it found that the defects could not be cured by amendment. It dismissed the action, directed the Clerk of Court to enter judgment, and certified that any appeal would not be taken in good faith; fee-free status was therefore denied for purposes of an appeal.