Lamb v. Cuomo
17-144-cv
| 2d Cir. | Oct 2, 2017Background
- Pro se plaintiffs Deborah Lamb and John Mecca sued multiple New York State and Suffolk County officials under 42 U.S.C. § 1983; claims were dismissed sua sponte by the district court.
- District Court (Seybert, J.) dismissed the complaint as frivolous despite plaintiffs having paid the filing fee.
- Plaintiffs appealed the dismissal to the Second Circuit, arguing the district court erred in dismissing their suit.
- The Second Circuit assumed familiarity with the record and evaluated whether the complaint lacked an arguable basis in law or fact.
- The appellate court applied the special solicitude owed to pro se pleadings but found the allegations “irrational” and “wholly incredible.”
- Because the pleadings were wholly incredible, the court concluded amendment would be futile and affirmed the district court’s dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a district court may sua sponte dismiss a paid‑fee complaint as frivolous | Lamb contends dismissal was improper and that her claims should proceed | Defendants contend complaint is frivolous and lacks any arguable basis | Affirmed: dismissal proper because claims lacked an arguable basis in law or fact |
| Standard for evaluating pro se pleadings | Pro se status requires leniency and at least one chance to amend | Defendants argue leniency does not prevent dismissal of wholly incredible claims | Court applied pro se solicitude but found allegations irrational; leniency not dispositive |
| Whether leave to amend was required | Lamb argues she should have been given opportunity to amend | Defendants argue amendment would be futile given the nature of the claims | Affirmed: leave to amend would be futile given wholly incredible allegations |
Key Cases Cited
- Fitzgerald v. First E. Seventh St. Tenants Corp., 221 F.3d 362 (2d Cir. 2000) (discusses review standard for sua sponte dismissal of paid‑fee complaints)
- Neitzke v. Williams, 490 U.S. 319 (1989) (defines frivolous claims as lacking an arguable basis in law or fact)
- Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (leave to amend not required when amendment would be futile)
- Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (articulates special solicitude for pro se pleadings)
- Denton v. Hernandez, 504 U.S. 25 (1992) (a court may dismiss claims that are irrational or wholly incredible)