Greene v. LA Care Health Plan
4:25-cv-00479
E.D. Mo.Apr 10, 2025Background
- Plaintiff, Cedric Greene, acting pro se, sought to file suit against LA Care Health Plan in the Eastern District of Missouri, requesting to proceed in forma pauperis.
- Greene’s complaint arose from denial of a housing certificate in California, after failed attempts to resolve his issue through the Better Business Bureau and Los Angeles County authorities.
- Greene has filed numerous, duplicative lawsuits in multiple federal courts nationwide, leading to filing restrictions and dismissals for abuse of the judicial process.
- The same, or nearly identical, claims were previously dismissed in other federal districts, including the Northern District of Illinois and the Northern District of Indiana, for improper venue and other procedural grounds.
- Greene's complaint failed to cite any federal statutes or constitutional provisions and did not allege proper venue or citizenship for jurisdiction in the Eastern District of Missouri.
- The Court identified this action as yet another attempt at forum shopping and harassment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can the Court review and reverse a California state court decision? | Greene seeks federal review of an adverse state court decision regarding housing. | LA Care Health Plan: Federal court lacks authority to review state court judgments (implied by dismissal). | No; barred by the Rooker-Feldman doctrine. |
| Is venue proper in the Eastern District of Missouri? | Greene hopes Missouri will accept the case despite no relevant connection. | LA Care Health Plan: No events or parties have connections to Missouri (implied). | No; venue is improper. |
| Has Greene stated a claim upon which relief can be granted under federal law? | Greene claims harm from LA Care's actions but cites no federal law. | LA Care Health Plan: No actionable federal claim is alleged (implied). | No; complaint fails to state a claim. |
| Is the case abusive or malicious litigation? | Greene asserts legitimacy of his repeated filings. | LA Care Health Plan: The filings are repetitive, abusive, and for harassment (implied). | Yes; action is dismissed as malicious. |
Key Cases Cited
- D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (the Rooker-Feldman doctrine precludes federal review of state court judgments)
- Rooker v. Fid. Trust Co., 263 U.S. 413 (federal courts have no appellate jurisdiction over state court decisions)
- Alpern v. Lieb, 38 F.3d 933 (must appeal state court decisions rather than bring new suit in federal court)
