Kane v. New York State Unified Court System, 1:25-cv-03595

Nickie Kane, a pro se disabled transgender woman, sued the New York State Unified Court System, the State of New York, several judges, and court staff, seeking prospective declaratory relief for alleged civil rights violations related to her treatment in prior and ongoing state court cases.
Kane alleged discrimination, harassment, and retaliation by judges and court personnel, including issuing restrictive litigation bars that required her to obtain leave before filing new cases or motions in Kings County Supreme Court.
This is at least the third lawsuit Kane has filed in the Eastern District of New York raising similar claims about judicial and court staff conduct in connection with her state court litigation, including prior unsuccessful challenges to similar litigation bars.
Kane also sought a temporary injunction to prevent enforcement of the latest litigation bar so that she could intervene in an election-related court proceeding in which she stated she was a candidate.
The amended complaint added some court administrators as defendants and asserted a common law negligence claim, but the crux of the case remained complaints against state judicial and court administrative action.
The Court granted Kane’s request to proceed in forma pauperis but denied the temporary injunction and dismissed the amended complaint in its entirety.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Injunctive relief against litigation bar	Kane argued she needs relief to intervene in state matters and challenges the litigation bar as blocking legal recourse	Injunctive relief was barred under the Anti-Injunction Act and judicial immunity; no valid exception applies	Court denied injunctive relief
Eleventh Amendment Immunity for State Defendants	Kane sought relief against the State and its Unified Court System	State entities are immune from suit under the Eleventh Amendment	Claims dismissed
Judicial Immunity for Judge Defendants	Kane alleged judges retaliated, discriminated, and exceeded authority	Judges acted within judicial capacity, are absolutely immune	Claims dismissed
Claims Against Court Staff and Administrators	Kane alleged improper docketing, non-responsiveness to complaints	Clerks/admins are immune for judicial/administrative tasks; no personal involvement shown	Claims dismissed

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets the plausibility standard for federal pleading)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must allege facts allowing for reasonable inference of liability)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se pleadings are construed liberally)
Atlantic Coast Line R. Co. v. Brotherhood of Locomotive Eng'rs, 398 U.S. 281 (1970) (Anti-Injunction Act bars most federal interference in state proceedings)
Mitchum v. Foster, 407 U.S. 225 (1972) (limited exceptions to the Anti-Injunction Act for §1983 cases)
Mireles v. Waco, 502 U.S. 9 (1991) (absolute judicial immunity for acts performed within judicial capacity)
Estelle v. Gamble, 429 U.S. 97 (1976) (pro se pleadings receive less stringent scrutiny)