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Zayas v. City of Seattle
2:24-cv-01613
| W.D. Wash. | Nov 19, 2024
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Background

  • Plaintiff Myriam Zayas filed suit against the City of Seattle and others, relating to her adult son’s death.
  • Plaintiff was granted leave to proceed in forma pauperis and filed her initial complaint.
  • The Court found the original complaint did not establish standing or state a cognizable claim under 42 U.S.C. § 1983 and ordered Zayas to amend.
  • Plaintiff filed an amended complaint, which mostly repeated prior arguments and failed to address the Court’s directions, particularly regarding standing and factual support for her claims.
  • The Court reviewed the amended complaint sua sponte and found it still deficient under federal pleading standards (Rule 8, Rule 12(h)(3)), and lacking subject matter jurisdiction and a valid claim for relief.
  • The complaint was dismissed without prejudice, and further leave to amend was denied due to futility.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Standing to Sue for Son’s Death Zayas asserts right to litigate son’s death Not provided Zayas lacks standing; injury not established
Sufficient Federal Claim (§ 1983) Alleges rights violations under § 1983 Not provided No plausible § 1983 claim stated
Identification of Violator Alleges misconduct generally Not provided No specific person identified
Pleading Standard Compliance Amended, added arguments Not provided Fails Rule 8; lacks facts or legal theory

Key Cases Cited

  • Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (describes constitutional standing requirements for federal court)
  • Clapper v. Amnesty Int’l USA, 568 U.S. 398 (2013) (injury for standing must be actual or imminent)
  • Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must state facially plausible claim for relief)
  • Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleadings must include enough facts to raise claim above speculative level)
  • Erickson v. Pardus, 551 U.S. 89 (2007) (pro se pleadings are to be liberally construed)
Read the full case

Case Details

Case Name: Zayas v. City of Seattle
Court Name: District Court, W.D. Washington
Date Published: Nov 19, 2024
Docket Number: 2:24-cv-01613
Court Abbreviation: W.D. Wash.