Daniels v. The City of New York

CourtDistrict Court, E.D. New York
DecidedJune 5, 2025
Docket1:25-cv-03341
StatusUnknown

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

Bluebook
Daniels v. The City of New York, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES EX REL. MARILYN DANIELS, Plaintiff, 1:25-CV-3658 (LTS) -against- ORDER THE CITY OF NEW YORK, et al., Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: By order dated May 9, 2025, and entered on May 12, 2025, the Court explained that Plaintiff, who appears pro se, could not proceed pro se with respect to her qui tam claims purportedly brought under the False Claims Act (“FCA”), and granted her 30 days’ leave to either: (1) retain an attorney to represent her in this action; or (2) withdraw this action. (ECF 2.) The Court warned Plaintiff that, if she did neither, the Court would dismiss this action without prejudice. (Id.) The Court also informed Plaintiff that, if she wanted to proceed pro se as to any non-FCA claims arising from the same facts, she could do so by bringing a separate civil action. (Id.) Moreover, in that order, and following an in camera review of Plaintiff’s complaint, the Court further directed that the seal normally applied to an FCA action be lifted as to that order and as to all subsequently filed documents in this action, but directed Plaintiff, as to any subsequently filed documents, to refer to the defendants as “sealed defendants.”1 (Id.) The Court additionally lifted the seal as to Plaintiff’s identity and mailing address, and directed the Clerk of Court to list Plaintiff’s name and mailing address on the court’s public docket of this action. (Id.)

1 The Court also informed Plaintiff that, if she filed any subsequent documents in this action in which she reveals the defendants’ names before this action is fully unsealed, public access to those documents would be restricted. (ECF 2.) In response to that order, Plaintiff filed, on May 22, 2025, May 30, 2025, and on June 4, 2025, numerous submissions essentially challenging that order.2 (ECF 3-14, 17-18.) The Court liberally construes all of those submissions as one motion for reconsideration brought under Local Civil Rule 6.3.3 See Tracy v. Freshwater, 623 F.3d 90, 101 (2d Cir. 2010) (the solicitude

afforded to pro se litigants takes a variety of forms, including liberal construction of papers, “relaxation of the limitations on the amendment of pleadings,” leniency in the enforcement of other procedural rules, and “deliberate, continuing efforts to ensure that a pro se litigant understands what is required of him” (citations omitted)). For the reasons set forth below, the Court: (1) denies that motion; (2) dismisses Plaintiff’s qui tam claims purportedly raised under the FCA without prejudice; (3) directs the Clerk of Court to completely unseal this action and to make publicly available, including on the court’s electronic docket of this action, Plaintiff’s initial filings in this action, including her (a) complaint, (b) “Notice and Motion to Proceed Pursuant to the First Bill of Right of the supreme Law of the Land without paying fees to Access the Article III court,” (c) application to proceed without prepaying fees or costs (her in forma

pauperis application), and (d) civil cover sheet; (4) directs the Clerk of Court to lift any other electronic-access restrictions on any of Plaintiff’s already docketed submissions; and (5) transfers Plaintiff’s remaining claims, including any claims under 42 U.S.C. §§ 1983, 1985,

2 Because of some of those submissions actually reveal the names of the defendants, the Court directed the Clerk of Court to, until the issuance of this order, restrict those submissions’ accessibility on the court’s electronic docket to a “case participant-only” basis. (See ECF 6, 13, 14.) 3 Under Local Civil Rule 6.3, a motion for reconsideration must be filed within 14 days after entry of the order being challenged. Here, the Court’s order being challenged was entered on May 12, 2025. Thus, Plaintiff needed to file a timely motion for reconsideration to challenge that order on or before May 26, 2025. Because all of Plaintiff’s submissions mentioned above essentially challenge the Court’s order, and though only some of them were filed on or before May 26, 2025, in light of Plaintiff’s pro se status, the Court construes all of those submissions filed after May 26, 2025, as supplements and/or amendments to those filed before that date. and 1986, and any under state law, to the United States District Court for the Eastern District of New York. DISCUSSION A. Relief under Local Civil Rule 6.3 The Court must deny Plaintiff’s motion. A party who seeks reconsideration relief under Local Civil Rule 6.3 must demonstrate that the Court overlooked “controlling law or factual

matters” that had been previously put before it. R.F.M.A.S., Inc. v. Mimi So, 640 F. Supp. 2d 506, 508-09 (S.D.N.Y. 2009). “Such motions must be narrowly construed and strictly applied in order to discourage litigants from making repetitive arguments on issues that have been thoroughly considered by the court.” Range Road Music, Inc. v. Music Sales Corp., 90 F. Supp. 2d 390, 391- 92 (S.D.N.Y. 2000); see also SimplexGrinnell LP v. Integrated Sys. & Power, Inc., 642 F. Supp. 2d 206, 209-10 (S.D.N.Y. 2009) (“[A] motion for reconsideration [under Local Civil Rule 6.3] is not an invitation to parties to ‘treat the court’s initial decision as the opening of a dialogue in which [the moving] party may then use such a motion to advance new theories or adduce new evidence in response to the court’s ruling.’” (citations omitted)).

As the Court noted in its previous order, the United States Court of Appeals for the Second Circuit has made clear that a litigant cannot proceed pro se with regard to qui tam claims brought under the FCA. See United States ex rel. Mergent Servs. v. Flaherty, 540 F.3d 89, 93 (2d Cir. 2008). While the Court understands that Plaintiff disagrees with the holding of the Court of Appeals in Flaherty, it is the controlling law of this Circuit with regard to Plaintiff’s qui tam claims purportedly raised under the FCA. The Court therefore denies Plaintiff reconsideration relief under Local Civil Rule 6.3. Because Plaintiff cannot proceed pro se with respect to her qui tam claims purportedly made under the FCA, and because, despite the Court’s granting of leave to Plaintiff to either retain an attorney to pursue these claims or withdraw this action, Plaintiff still proceeds with these claims pro se, the Court dismisses these claims without prejudice. Accordingly, because the information provided by Plaintiff does not fall within the statute requiring sealing, see 31 U.S.C. § 3720(a), (b)(2), there is no reason why any part of this action should remain sealed. The Court

therefore directs the Clerk of Court to completely unseal this action and to make publicly available, including on the court’s electronic docket of this action, Plaintiff’s initial filings in this action, including her complaint, “Notice and Motion to Proceed Pursuant to the First Bill of Right of the supreme Law of the Land without paying fees to Access the Article III court,” application to proceed without prepaying fees or costs, and civil cover sheet. The Court also directs the Clerk of Court to lift any other electronic-access restrictions on any of Plaintiff’s already docketed submissions. B.

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Tracy v. Freshwater
623 F.3d 90 (Second Circuit, 2010)
United States Ex Rel. Mergent Services v. Flaherty
540 F.3d 89 (Second Circuit, 2008)
Simplexgrinnell Lp v. Integrated Systems & Power, Inc.
642 F. Supp. 2d 206 (S.D. New York, 2009)
R.F.M.A.S., Inc. v. Mimi So
640 F. Supp. 2d 506 (S.D. New York, 2009)
Range Road Music, Inc. v. Music Sales Corp.
90 F. Supp. 2d 390 (S.D. New York, 2000)
Keitt v. New York City
882 F. Supp. 2d 412 (S.D. New York, 2011)

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Bluebook (online)
Daniels v. The City of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-the-city-of-new-york-nyed-2025.