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Manchanda v. Attorney Grievance Committee 1st Department
1:25-cv-03935
S.D.N.Y.
May 16, 2025
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Background

  • Plaintiff, Rahul Dev Manchanda, filed a new lawsuit in the Southern District of New York against the Attorney Grievance Committee and the NYS Supreme Court Appellate Division, 1st Department.
  • On February 5, 2024, Manchanda was subject to a filing injunction in the Southern District of New York, requiring court permission before any new lawsuits could be filed.
  • The injunction mandated five specific procedural requirements for seeking leave to file any new action within the district.
  • Manchanda’s earlier appeal of the filing injunction was dismissed by the Second Circuit as lacking any arguable basis in law or fact.
  • In this new action, Manchanda did not fulfill the required steps set forth in the February 2024 injunction.
  • The action was initially filed in the Northern District of New York and then transferred to the Southern District, which reviewed compliance with the injunction.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Compliance with filing injunction No argument addressing compliance Injunction must be enforced Dismissed for non-compliance
Leave of court to file new action Implicitly sought by filing Leave procedures must be followed Dismissed, leave not properly sought
Payment of filing fee as sufficient Fee paid; no further requirements Procedural requirements trump fees Fee payment insufficient for filing
Good faith basis for appeal (IFP status) Not specified Dismissal not in good faith IFP status for appeal denied

Key Cases Cited

  • Coppedge v. United States, 369 U.S. 438 (1962) (sets the standard for determining when an appeal is taken in good faith for purposes of IFP status)
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Case Details

Case Name: Manchanda v. Attorney Grievance Committee 1st Department
Court Name: District Court, S.D. New York
Date Published: May 16, 2025
Docket Number: 1:25-cv-03935
Court Abbreviation: S.D.N.Y.