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