Green v. Matsumoto
1:22-cv-03685
| E.D.N.Y | Jun 27, 2022Background
- Plaintiff Lawrence Green, proceeding pro se and IFP, filed the instant suit alleging fraud related to prior Social Security litigation and naming several federal judges and an SSA employee (Frederick Maurin) as defendants.
- The complaint is rooted in an initial 2014 Social Security benefits appeal and multiple subsequent suits (five prior actions in this District) challenging SSA procedures and court handling of those cases.
- Several prior actions by Green were dismissed by different judges for failure to state a claim or on immunity grounds; the district court previously dismissed claims against Maurin with prejudice.
- This complaint was construed as asserting Bivens claims against the judicial defendants and Maurin but was sparse and conclusory in factual allegations.
- The Court dismissed the complaint with prejudice under 28 U.S.C. § 1915(e)(2)(B) as barred by judicial immunity and claim preclusion, denied leave to amend as futile, and warned Green about potential future filing restrictions; IFP for appeal was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims against federal judges are actionable | Green alleges fraud and seeks relief under Bivens against judges | Judicial and quasi-judicial immunity bars suits for acts in their judicial capacity | Dismissed: absolute judicial/quasi-judicial immunity applies; claims barred |
| Whether claims against Maurin are precluded | Green reasserts claims previously brought against Maurin | Prior dismissal of Maurin's claims with prejudice precludes relitigation | Dismissed: claim precluded by prior adjudication |
| Whether complaint states a plausible claim under Rule 8/Iqbal/Twombly | Green alleges fraud but provides few factual details | Complaint is conclusory and lacks factual enhancement to show plausibility | Dismissed: fails to state a plausible claim under §1915(e)(2)(B) |
| Whether to grant leave to amend | Green could amend to add facts | Court notes repetitive, previously adjudicated claims and low likelihood amendment would cure defects | Denied: amendment would be futile; dismissal with prejudice |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (recognizing implied damages action against federal officers)
- Mireles v. Waco, 502 U.S. 9 (judicial immunity protects judges for judicial acts)
- Forrester v. White, 484 U.S. 219 (limits to judicial immunity for nonjudicial actions)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state plausible claim)
- Bliven v. Hunt, 579 F.3d 204 (acts related to individual cases are judicial in nature)
- Ruffolo v. Oppenheimer & Co., 987 F.2d 129 (leave to amend need not be granted when futile)
- Cuoco v. Moritsugu, 222 F.3d 99 (amendment may be denied if futile)
- Hong Mai Sa v. Doe, 406 F.3d 155 (courts may restrict future filings by vexatious litigants)
- Coppedge v. United States, 369 U.S. 438 (standard for good-faith appeal under IFP)