Abdulai Kure v. State of New York; TLC (Taxi and Limo); Park & Nguyen Law Office

District Court, S.D. New York·Decided July 22, 2026·No. 1:26-cv-03942·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ABDULAI KURE, Plaintiff, 26 Civ. 3942 (JHR) -against- ORDER OF SERVICE STATE OF NEW YORK; TLC (TAXI AND LIMO); PARK & NGUYAN LAW OFFICE, Defendants. JENNIFER H. REARDEN, District Judge: Plaintiff, appearing pro se, brings this action under the Court’s federal question jurisdiction, 28 U.S.C. § 1331, alleging that officers of the New York City Taxi & Limousine Commission (the “TLC”) falsely arrested him and used excessive force against him. ECF No. 1 (Compl.). The Court liberally construes the complaint as asserting claims under 42 U.S.C. § 1983 and New York state law. On June 2, 2026, the Honorable Laura Taylor Swain granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. ECF No. 5. For the reasons that follow, the Court (1) dismisses, on sovereign immunity grounds, all claims against the State of New York; (2) dismisses, for failure to state a claim, all claims against Park & Nguyen Law Office; (3) dismisses, for failure to state a claim, all claims against the TLC, and substitutes in its place, pursuant to Rule 21 of the Federal Rules of Civil Procedure, the City of New York; (4) adds as Defendants, also pursuant to Rule 21, Officer A. Robert, Lt. A. Kolasny, and six John Doe TLC officers; (6) directs the TLC and the New York City Law Department, under Valentin v. Dinkins, to identify the John Doe TLC officers; and (7) directs service on the identified Defendants. LEGAL STANDARD The Court “shall” dismiss an IFP complaint, or any portion thereof, that “the court determines” is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998)

(“A district court must dismiss an in forma pauperis action if the action is ‘frivolous or malicious.’”). The Court must also dismiss a complaint “[i]f the court determines at any time that it lacks subject-matter jurisdiction.” Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of those grounds, the Court is “obligated to construe [] pro se [pleadings] liberally,” Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and to interpret them to raise the “strongest arguments that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits—to state a claim, “[a]ll pleadings, including those filed by pro se litigants, must comply with Rule 8(a) of the Federal Rules of Civil Procedure,” Brewer v. Burns, No. 23 Civ. 9605 (LTS), 2023 WL

8603083, at *2 (S.D.N.Y. Dec. 11, 2023). “Rule 8 requires that a plaintiff allege in its complaint ‘enough facts to state a claim to relief that is plausible on its face.’” Panther Partners Inc. v. Ikanos Commc’ns, Inc., 347 F. App’x 617, 619 (2d Cir. 2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the pleaded factual content allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 663 (2009). “When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. at 679. But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which essentially are legal conclusions. Twombly, 550 U.S. at 555. DISCUSSION A. Defendant the State of New York Plaintiff names the State of New York as a Defendant. “[A]s a general rule, state governments may not be sued in federal court unless they have waived their Eleventh

Amendment immunity, or unless Congress has abrogated the states’ Eleventh Amendment immunity . . . .” Gollomp v. Spitzer, 568 F.3d 355, 366 (2d Cir. 2009) (internal quotation and citation omitted). “The immunity recognized by the Eleventh Amendment extends beyond the states themselves to state agents and state instrumentalities that are, effectively, arms of a state.” Id. (internal quotations and citation omitted). “Congress did not abrogate the States’ sovereign immunity when it enacted §§ 1983 and 1985, and New York has not waived its immunity.” Walker v. NYS Just. Ctr. for Prot. of People with Special Needs, 493 F. Supp. 3d 239, 246 (S.D.N.Y. 2020) (collecting cases) (dismissing claims against the State of New York). Plaintiff’s claims against the State of New York are therefore barred by the Eleventh Amendment and are hereby dismissed.

B. Defendant Park & Nguyen Law Office1 Plaintiff alleges that he “previous[ly] file[d] a case against the TLC[, but] before [he could] get a response from the court[, t]he law firm of Park & Nguyen sen[t him] a mail stat[ing] that the case has been schedule[d] for hearing[,] which was false.” Compl. at 5. Plaintiff added

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