Joseph v. Jamaica Hospital Medical Center, 1:21-cv-02137

Pro se plaintiff Anderson Joseph filed four consolidated suits under 42 U.S.C. § 1983 against Jamaica Hospital Medical Center, Mount Sinai Queens, NYU (Medical Business Office), and Queens Hospital Center alleging medical malpractice and discrimination arising from pregnancy and newborn care.
Allegations include: a newborn kept seven days with abnormal symptoms; a nurse "in training" causing heavy bleeding from a pregnant wife; an alleged delayed delivery leading to an infant’s apparent death and later resuscitation; and lack of seating/beds and resulting stress during a prenatal visit.
Joseph sought large damages ($5 million to $100 million) and claimed discrimination; complaints were liberally construed as pro se filings.
The Court granted in forma pauperis status but found the private hospitals’ actions not pleaded as state action and concluded the claims amounted to state-law medical malpractice.
The Court dismissed the complaints under 28 U.S.C. § 1915(e)(2)(B) for failure to state a § 1983 claim and for lack of federal jurisdiction (no federal-question or complete diversity).
The Court denied leave to amend as futile, warned Joseph about future vexatious filings, and certified that any appeal would not be taken in good faith (denying IFP status for appeal).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1983 applies to private hospitals	Joseph alleges hospitals committed malpractice and discrimination under color of law	Hospitals are private and not acting under color of state law	Dismissed: private hospitals not shown to be state actors; § 1983 claim fails
Whether federal courts have jurisdiction over the malpractice claims	Joseph framed complaints as federal civil-rights/discrimination claims	Claims are medical malpractice under state law; no diversity or federal question jurisdiction	Dismissed for lack of subject-matter jurisdiction
Whether pro se plaintiff should get leave to amend	Joseph entitled to liberal construction and opportunity to amend	Court: defects are substantive and cannot be cured by repleading	Denied: amendment would be futile
Whether court should restrict future filings or impose sanctions	(No substantive opposing argument filed)	Court may limit vexatious, frivolous litigation to protect docket	Warning issued that future frivolous filings may prompt an injunction or sanctions

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (court may disregard legal conclusions in pleadings)
Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40 (1999) (private conduct generally not actionable under § 1983 absent state action)
Rendell-Baker v. Kohn, 457 U.S. 830 (1982) (tests for attributing private entity conduct to the state)
Fabrikant v. French, 691 F.3d 193 (2d Cir. 2012) (describes compulsion, joint-action, and public-function tests for state action)
Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (leave to amend not required where amendment would be futile)
Baker v. McCollan, 443 U.S. 137 (1979) (§ 1983 is a procedural vehicle for vindicating federal rights)
Coppedge v. United States, 369 U.S. 438 (1962) (standard for finding an appeal not taken in good faith)