Ruiz v. The City of New York Commission on Human Rights

Background

Angel Ruiz, proceeding without a lawyer, sued the City of New York Commission on Human Rights and two employees, Jacquline Rios and “Anthony.” Ruiz alleged that he reported an alleged hate crime to the Commission in January 2021, that the Commission contacted him about eight months later, and that Rios did not obtain various records and video footage that Ruiz believed were relevant. Ruiz alleged that the defendants’ conduct caused mental and physical trauma, affected his disability, caused fear for his safety, and left him homebound for 18 months. He sought money damages.

Ruiz invoked diversity jurisdiction. The court had previously allowed him to proceed without paying filing fees upfront and therefore screened the complaint under the federal statute governing such cases.

Diversity jurisdiction

The court held that Ruiz did not allege facts establishing diversity jurisdiction. Diversity jurisdiction generally requires the parties to be citizens of different states and requires the amount in dispute to exceed $75,000. Ruiz identified himself as a New York citizen and sued a New York City agency. Because he sued an agency of New York City, the court held that complete diversity could not exist. Ruiz also did not allege the citizenship of the two employees.

Constitutional claim

Because Ruiz’s allegations could implicate constitutional rights, the court construed them as claims under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by people acting under state authority. The court treated his allegation that the defendants failed to adequately investigate his hate-crime report as a possible procedural due-process claim.

The court held that the Constitution does not provide a general right to an adequate government investigation. It identified two exceptions: when officials take and hold a person against that person’s will, and when officials affirmatively create or increase a danger to a plaintiff. The court held that Ruiz alleged no facts showing that either exception applied. It therefore dismissed the § 1983 claims for failure to state a claim on which relief could be granted.

State-law claims and amendment

Although the court could consider state-law claims through supplemental jurisdiction while federal claims remained, it declined to exercise that jurisdiction after dismissing all claims over which it had original jurisdiction. The court also denied leave to amend because it concluded that the defects in the complaint could not be cured by amendment.

Disposition

The court dismissed Ruiz’s complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). It terminated all other pending matters and directed the Clerk of Court to enter judgment. The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.