Dan v. Hochul

CourtDistrict Court, N.D. New York
DecidedOctober 2, 2025
Docket1:25-cv-00122
StatusUnknown

This text of Dan v. Hochul (Dan v. Hochul) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dan v. Hochul, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ____________________________________________

CHONG LEE DAN,

Plaintiff, vs. 1:25-cv-00122 (MAD/PJE) KATHY HOCHUL, Governor of New York,

Defendant. ____________________________________________

APPEARANCES: OF COUNSEL:

CHONG LEE DAN Cairo, New York 12413 Plaintiff pro se

OFFICE OF THE NEW YORK THOMAS A. CULLEN, ESQ. STATE ATTORNEY GENERAL The Capitol Albany, New York 12224 Attorney for Defendant

Mae A. D'Agostino, U.S. District Judge:

MEMORANDUM-DECISION AND ORDER I. INTRODUCTION Plaintiff commenced this action on January 27, 2025, alleging thirteen causes of action against New York Governor Kathy Hochul after a traffic stop in Greene County, New York. Dkt. No. 1. He filed an amended complaint on February 5, 2025. Dkt. No. 7. On March 5, 2025, Plaintiff filed a motion for declaratory judgment regarding subject matter jurisdiction. Dkt. No. 11. On April 14, 2025, Defendant filed a motion to dismiss the amended complaint. Dkt. No. 17. On July 2, 2025, while the motion to dismiss and motion for declaratory judgment were still pending, Plaintiff filed a motion for the Court to take judicial notice of excerpts from various sources of legal authority. Dkt. No. 23. The Court addresses these motions in turn. II. BACKGROUND On March 15, 2024, Plaintiff visited a gas station in Cairo, New York, to purchase fuel for his 2005 Chevrolet Astro van. Dkt. No. 7 at ¶¶ 15-16. Plaintiff, who is homeless, sleeps in his van at night and has mailing addresses in Pennsylvania and Texas. Id. at ¶¶ 47, 79. He also adamantly insists that the van is not a "vehicle," as legally defined, and instead refers to it as "private property for personal, family, or household purposes . . . ." Id. at ¶¶ 15, 63, 65.

Likewise, Plaintiff maintains that his operation of the van does not amount to "driving." Id. at ¶¶ 27-30. Rather, according to Plaintiff, his operation of the van constitutes "traveling." Id. Thus, because Plaintiff purportedly travels in the van instead of driving it, and because the van is not a vehicle, Plaintiff argues that he does not need a valid driver's license or vehicle registration to operate the van in New York. Id. at ¶¶ 25-35, 48. As Plaintiff was preparing to enter the gas station's convenience store, Greene County Sheriff's Deputy Ryan Schrader approached Plaintiff. Deputy Schrader told Plaintiff that the Maryland registration tag on the van was expired. Id. at ¶ 19. In response, Plaintiff told the deputy that the van was not required to have a valid registration tag. Id. at ¶ 20. Plaintiff also produced a document purportedly filed in the Caldwell County, North Carolina Register of Deeds,

which Plaintiff quotes in the amended complaint. Id. at ¶¶ 23-23.12. That document claims to cite various federal statutes and regulations, the U.S. Constitution, and Supreme Court precedent for their interpretations of terms like "vehicle," "motor vehicle," "travel," and "drive." Id. It also proclaims, "I believe anyone with an oath to support the Federal Constitution that fails to operate the term 'motor vehicle' as constitutionally defined commits perjury of that oath and acts against Me without authority." Id. at ¶ 23.12. After receiving the North Carolina document, Deputy Schrader told Plaintiff, "A driver's license and registration are required to drive in New York." Id. at ¶ 25. Plaintiff replied, "If you are driving, Officer." Id. at ¶ 26. The deputy responded, "I absolutely witnessed you driving." Id. at ¶ 27. Plaintiff claimed he was traveling, not driving, and challenged Deputy Schrader's understanding of the definition of "driving." Id. at ¶¶ 30-31. When Deputy Schrader asked whether Plaintiff had a valid driver's license, Plaintiff answered, "No, I do not because I don't

need one." Id. at ¶ 35. He also repeatedly referred Deputy Schrader to the North Carolina document. Id. at ¶¶ 34, 38. As the interaction wore on, Plaintiff and Deputy Schrader continued to disagree. Plaintiff asked Deputy Schrader, "Do you have any evidence that I am driving a motor vehicle as defined by the United States Code?" Id. at ¶ 48. The deputy answered in the affirmative, but when Plaintiff demanded evidence to that effect, Deputy Schrader did not respond. Id. at ¶¶ 49-51. Eventually, Deputy Schrader reiterated to Plaintiff that "in New York State, you got [to] have a driver's license to operate a motor vehicle . . . [a]nd you also have to have a valid registration on [the] vehicle . . . ." Id. at ¶ 53. Because Plaintiff had neither, Deputy Schrader told him he could not operate the van on New York highways. Id. at ¶ 54. The deputy issued two

citations to Plaintiff, and the van was towed. Id. at ¶¶ 55-56. The van's impoundment left Plaintiff without transportation or a place to sleep. Id. at ¶ 79. He then began living in a tent on some friends' property. Id. at ¶¶ 81-82. Plaintiff pled not guilty to the ticketed violations. Id. at ¶ 90. The Cairo Town Court eventually dismissed the charges because Deputy Schrader did not provide a supporting deposition. Id. at ¶ 92. Nevertheless, Plaintiff contends that he was wrongly denied the right to a hearing regarding seizure of his property. Id. at ¶ 94. He also unsuccessfully sought assistance from the Cairo Town Court, Greene County Public Defender, Greene County District Attorney, and other local officials to get his van back. Id. at ¶¶ 97-99. Plaintiff then attended a hearing with counsel for the county, where he claims the county attorney "engaged in frivolous arguments with the Plaintiff to confuse the commercial versus non-commercial use of the New York public roads." Id. at ¶¶ 107, 109. On June 25, 2024, Plaintiff filed a document with the Greene County Clerk's Office,

alleging a "seditious conspiracy to overthrow the Constitution and violate the Plaintiff's God- given rights." Id. at ¶ 111. He named twelve Greene County employees as co-conspirators and tried to contact the governor with a request for protection from the conspiracy. Id. at ¶¶ 111.1- 111.12, 115. Plaintiff did not receive a response, and now believes that Governor Hochul is involved in the conspiracy. Id. at ¶ 116. Plaintiff asserts thirteen causes of action against Governor Hochul: (1) deprivation of rights under 42 U.S.C. § 1983; (2) conspiracy to interfere with civil rights under 42 U.S.C. § 1985; (3) malicious prosecution under 42 U.S.C. § 1983; (4) failure to prevent a conspiracy to interfere with civil rights under 42 U.S.C. § 1986; (5) forced labor under 18 U.S.C. § 1589; (6) robbery under New York Penal Law § 160.10; (7) false imprisonment (without specifying

whether the claim is civil or criminal); (8) coercion under New York Penal Law § 135.60; (9) official misconduct under New York Penal Law § 195.00; (10) libel; (11) slander; (12) assault under New York Penal Law § 120.00; and (13) intentional infliction of emotional distress ("IIED"). Dkt. No. 7. He seeks compensatory damages encompassing the daily average cost of a van rental in New York, the average cost of a room rental in Greene County, and his estimated lost earnings. Id. at 28. He also seeks $400,000 in punitive damages from Defendant, declaratory and injunctive relief against Defendant and several non-parties, and an award of attorney's fees. Id. at 29. III. DISCUSSION A.

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Dan v. Hochul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dan-v-hochul-nynd-2025.