Marvin v. Allen
7:23-cv-05947
S.D.N.Y.Jul 11, 2025Background
- Mark Marvin, proceeding pro se, filed suit against several individual defendants and the County of Orange, stemming from disputes concerning local tax matters and alleged denial of tax exemption.
- The District Court had previously granted Defendants’ motion to dismiss, finding the claims barred by the Tax Injunction Act (TIA) and otherwise not legally cognizable.
- Marvin filed a motion for reconsideration, arguing the Court erred and raising new and reiterated points in support of his position.
- The Court reviewed Marvin’s motion under Federal Rule of Civil Procedure 59(e) and relevant local rules, which set a high bar for reconsideration.
- The Court also examined whether there had been any intervening change in controlling law, new evidence, or clear error that might warrant disturbing its prior judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| TIA bars federal jurisdiction | TIA should not apply; local tax matter improperly dismissed | TIA plainly divests court of jurisdiction over plaintiff’s claims | Court agrees with defendants: TIA bars claim |
| Reconsideration motion standard | Court must reassess prior dismissal given alleged overlooked facts | No new law, facts, or clear error to revisit ruling | Standard not met; denial of motion |
| Reassertion of RICO/tax claims | Restates previous claims as RICO/framing of local tax disputes | Merely repackaged legal arguments previously rejected | Court finds these are relitigated, rejected issues |
| Alleged stipulations and Youngblood | Argues stipulations and Supreme Court precedent apply | No valid stipulations; cited precedent irrelevant | Record does not support plaintiff; cited case inapposite |
Key Cases Cited
- Shrader v. CSX Transp., Inc., 70 F.3d 255 (2d Cir. 1995) (sets strict limits on motions for reconsideration to prevent merely relitigating settled issues)
- Bernard v. Vill. of Spring Valley, 30 F.3d 294 (2d Cir. 1994) (confirms that the TIA is designed to limit federal interference in local tax disputes)
- Arizona v. Youngblood, 488 U.S. 51 (1988) (addresses due process and evidence preservation, deemed irrelevant to this case by the court)