Chris H. v. The State Of New York
1:17-cv-02902
S.D.N.Y.Dec 18, 2017Background
- Plaintiff Chris H. sued the State of New York and Justice Tandra Dawson claiming federal and state-law violations arising from a matrimonial actions proceedings.
- In April 2017 Dawson held a contempt hearing; plaintiff was ordered to pay an appraisal and was jailed for contempt after noncompliance.
- Plaintiff contends he was imprisoned in inhumane conditions, including lack of food, water, and sanitation, and was strip-searched during detention.
- Plaintiff had previously filed a separate action (No. 16-CV-6807) against Dawson and the State, which was dismissed in July 2017.
- Defendants moved to dismiss all claims under Rules 12(b)(1) and 12(b)(6); the court stayed discovery pending decision.
- The court granted the motion, dismissing federal claims against the State and Dawson in official capacity, and against Dawson in her individual capacity; declined supplemental jurisdiction over state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sovereign immunity bars federal claims against State and Dawson in official capacity | Plaintiff seeks relief under §1983/§1985 against state actors. | Eleventh Amendment immunity applies; no consent or waiver and no abrogation. | Counts dismissed against State and Dawson in official capacity. |
| Whether judicial immunity bars plaintiff's federal claims against Dawson in her individual capacity | Dawson violated rights in non-judicial conduct? | Dawson's actions were judicial, within jurisdiction and of a judicial nature. | Judicial immunity bars all federal claims against Dawson in her individual capacity. |
| Whether the court should exercise supplemental jurisdiction over remaining state-law claims | State-law claims arise from related proceedings and should proceed in federal court. | With federal claims dismissed, jurisdiction over state claims should not be exercised. | Court declined supplemental jurisdiction over state-law claims. |
Key Cases Cited
- Edelman v. Jordan, 415 U.S. 651 (U.S. 1974) (Eleventh Amendment sovereign immunity basics)
- Gollomp v. Spitzer, 568 F.3d 355 (2d Cir. 2009) (state sovereign immunity limitations in federal claims)
- Bd. of Trustees of Univ. of Alabama v. Garrett, 531 U.S. 356 (U.S. 2001) (abrogation/consent exceptions to sovereign immunity)
- Will v. Michigan Department of State Police, 491 U.S. 58 (U.S. 1989) (constitutional limitations on §1983 claims against states)
- Kentucky v. Graham, 473 U.S. 159 (U.S. 1985) (standard for individual-capacity supervisory damages against judges)
- Stump v. Sparkman, 435 U.S. 357 (U.S. 1978) (judicial immunity when actions are in judicial capacity)
- Trimarco v. Data Treasury Corp., 146 A.D.3d 1004 (2d Dep't 2017) (recusal and jurisdiction considerations for judges)
- Huminski v. Corsones, 396 F.3d 53 (2d Cir. 2005) (jurisdictional analysis for judicial immunity)
- LaFaro v. NY Cardiothoracic Group, PLLC, 570 F.3d 471 (2d Cir. 2009) (liberal construction of pro se complaints and plausibility requirement)