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S.D.N.Y.Procedural orderFiled Jan. 16, 2024

Jaime v. New York City Corrections

Judge
Laura Swain
Docket
1:24-cv-00271
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Jaime v. New York City Corrections, Judge Swain dismissed Luis Jaime’s duplicate lawsuit without prejudice and ordered that its filing fee not be charged.

Who this affects

Luis Jaime’s duplicate lawsuit was dismissed without prejudice. The defendants were not adjudicated on the merits, and Jaime was not charged the $350 filing fee for this action.

What happened

In Jaime v. New York City Corrections, Luis Jaime, who is incarcerated, sued under a federal civil-rights law. He alleged that the defendants violated his constitutional rights at a Manhattan courthouse on September 30, 2023.

The court found that Jaime had already brought a substantially similar case about the same events, which was still pending under docket number 24-CV-0266. The court said the new lawsuit served no useful purpose because it repeated claims in that earlier case.

Judge Laura Taylor Swain dismissed this lawsuit without prejudice to Jaime’s pending case. She also ordered that Jaime not be charged the $350 filing fee for this action, directed that no money be taken from his prison account for it, and denied payment-free status for an appeal.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Jaime v. New York City Corrections · No. 1:24-cv-00271
Judge
Laura Swain
Date
Jan. 16, 2024

Background

Luis Jaime, who was incarcerated at Sullivan Correctional Facility, filed this lawsuit without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims against persons who violate constitutional rights while acting under state authority. He alleged that the defendants violated his constitutional rights at a courthouse in Manhattan on September 30, 2023.

Reason for Dismissal

The court stated that Jaime had already filed a substantially similar lawsuit arising from the same September 30, 2023 events. That earlier related proceeding remained pending under docket number 24-CV-0266 (LTS). Although the defendants were not exactly the same in both lawsuits, the court noted that Jaime could amend the earlier case under Rule 15 of the Federal Rules of Civil Procedure to add defendants connected to the incident.

Because this lawsuit duplicated claims already raised in the pending action, the court concluded that filing and litigating it would serve no useful purpose. The court therefore dismissed the complaint without prejudice to Jaime’s pending case. The opinion did not decide whether Jaime’s constitutional claims were valid.

Other Orders and Disposition

Judge Laura Taylor Swain directed the Clerk of Court not to charge Jaime the $350 filing fee for this action. The court also directed that the official responsible for his custody not deduct or encumber money from his prison account for this lawsuit, so Jaime did not need to submit the prisoner authorization form for this case.

The court certified that an appeal would not be taken in good faith and denied payment-free status for purposes of an appeal. It directed the Clerk of Court to enter judgment. The case was dismissed without prejudice as duplicative of the pending action under docket number 24-CV-0266 (LTS).

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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