Singleton El Bey v. People of the State of New York
- Ronnie Abrams
- 1:24-cv-02208
- U.S. District Court · Southern District of New York
- 5
Singleton El Bey v. People of New York: Judge Abrams dismissed the complaint as frivolous and denied fee-free appeal status.
The dismissal ended Marzallah Martin-Drew Singleton El Bey’s federal civil action against The People of the State of New York. The opinion also denied fee-free status for any appeal.
What happened
In Singleton El Bey v. People of the State of New York, the plaintiff submitted documents without explaining a legally recognizable reason for filing them in federal court. The documents included notices, purported contracts, legal jargon, and other materials.
The court found that the complaint alleged no facts showing that anyone violated the plaintiff’s rights and identified no valid legal claim. It dismissed the complaint as frivolous because it lacked a factual basis and a workable legal theory.
Judge Ronnie Abrams also found that correcting the complaint through another filing would be futile, so the plaintiff was not given permission to amend. The court entered judgment and denied fee-free status for any appeal, certifying that an appeal would not be taken in good faith.
The detailed version
- Singleton El Bey v. People of the State of New York · No. 1:24-cv-02208
- Ronnie Abrams
- May 2, 2024
Background
Marzallah Martin-Drew Singleton El Bey initially filed the matter as a miscellaneous case on behalf of the “Martin Drew Singleton Trust/Estate.” The filing included a document apparently concerning a New York State Supreme Court matter, a miscellaneous-case cover sheet with inconsistent party designations, and other materials. Because the filing did not fit a miscellaneous-case category, the court directed that it be opened as a civil action naming Singleton El Bey as the plaintiff and The People of the State of New York as the defendant.
The submissions included two copies of a document titled “Conditional Acceptance and Opportunity to Cure,” documents containing legal and commercial terminology, purported signatures of several government officials, a birth certificate stamped “void,” a civil cover sheet, and a document titled “Actual and Constructive Notice of Default and Engagement into a Private Contract.” The opinion states that the submissions did not explain why the plaintiff was filing them in federal court.
Court’s Analysis
The court explained that it may dismiss a complaint as frivolous even when the filing fee has been paid. A claim is frivolous when it lacks a reasonable basis in fact or law. The court also stated that it must interpret filings by a person without a lawyer generously and consider the strongest claims the filings suggest.
The court concluded that the complaint consisted largely of incomprehensible legal and other jargon. It alleged no facts suggesting that anyone had violated the plaintiff’s rights and identified no viable legal cause of action. Because the complaint had no factual basis or legal theory on which the plaintiff could rely, the court dismissed it as frivolous.
Disposition
The court dismissed the complaint as frivolous. It concluded that the defects were substantive and that better pleading could not cure them, so it did not grant leave to amend. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied fee-free status for an appeal. The Clerk was directed to enter judgment.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.