Darling v. Facebook (META)

CourtDistrict Court, N.D. New York
DecidedJuly 1, 2025
Docket5:25-cv-00181
StatusUnknown

This text of Darling v. Facebook (META) (Darling v. Facebook (META)) 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
Darling v. Facebook (META), (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

MICHAEL D. DARLING,

Plaintiff,

v. 5:25-cv-0181 (AMN/TWD)

FACEBOOK (META),

Defendant.

APPEARANCES: OF COUNSEL:

MICHAEL D. DARLING 24-B-0396 Auburn Correctional Facility P.O. Box 618 Auburn, NY 13021 Plaintiff, pro se

Hon. Anne M. Nardacci, United States District Judge:

ORDER I. INTRODUCTION On February 10, 2025, Plaintiff pro se Michael D. Darling (“Plaintiff”) filed a complaint against Facebook (“Defendant”) related to certain posts in the Facebook group “Justice for Kristine.” Dkt. No. 1 (“Complaint”). Plaintiff sought and received leave to proceed in forma pauperis. Dkt. Nos. 2, 5, 6, 9. This matter was referred to United States Magistrate Thérèse Wiley Dancks, who reviewed the Complaint pursuant to 28 U.S.C. § 1915(e) and, on May 27, 2025, recommended that the Complaint be dismissed without prejudice and with leave to amend. Dkt. No. 9 (“Report- Recommendation”). Magistrate Judge Dancks advised that pursuant to 28 U.S.C. § 636(b)(1), the parties had fourteen days within which to file written objections and that failure to object to the Report-Recommendation within fourteen days would preclude appellate review. Id. at 10.1 Plaintiff filed objections on June 9, 2025. Dkt. No. 10. For the reasons set forth below, the Court rejects Plaintiff’s objections and adopts the Report-Recommendation in its entirety. II. STANDARD OF REVIEW

This Court reviews de novo those portions of a magistrate judge’s report-recommendation that have been properly preserved with a specific objection. 28 U.S.C. § 636(b)(1)(C). “To be ‘specific,’ the objection must, with particularity, ‘identify [1] the portions of the proposed findings, recommendations, or report to which it has an objection and [2] the basis for the objection.’” Petersen v. Astrue, 2 F. Supp. 3d 223, 228–29 (N.D.N.Y. 2012) (alteration in original) (quoting N.D.N.Y. Local Rule 72.1(c)). If no specific objections have been filed, this Court reviews a magistrate judge’s report-recommendation for clear error. See Petersen, 2 F. Supp. 3d at 229 (citing Fed. R. Civ. P. 72(b) advisory committee’s notes to 1983 addition). Similarly, when a party files “[g]eneral or conclusory objections, or objections which merely recite the same arguments

[previously] presented to the magistrate judge,” the district court reviews a magistrate judge’s report-recommendations for clear error. O’Diah v. Mawhir, No. 08-cv-322, 2011 WL 933846, at *1 (N.D.N.Y. Mar. 16, 2011) (citations omitted); accord Mario v. P & C Food Markets, Inc., 313 F.3d 758, 766 (2d Cir. 2002) (a “statement, devoid of any reference to specific findings or recommendations to which [the plaintiff] objected and why, and unsupported by legal authority, was not sufficient to preserve” a claim); Petersen, 2 F. Supp. 3d at 228–29 & n.6 (collecting cases). “When performing such a ‘clear error’ review, ‘the court need only satisfy itself that there is no

1 Citations to docket entries utilize the pagination generated by CM/ECF, the Court’s electronic filing system, and not the documents’ internal pagination. clear error on the face of the record in order to accept the recommendation.’” Dezarea W. v. Comm’r of Soc. Sec., No. 21-cv-01138, 2023 WL 2552452, at *1 (N.D.N.Y. Mar. 17, 2023) (quoting Canady v. Comm’r of Soc. Sec., No. 17-cv-0367, 2017 WL 5484663, at *1 n.1 (N.D.N.Y. Nov. 14, 2017)). “[I]n a pro se case, the court must view the submissions by a more lenient standard than

that accorded to ‘formal pleadings drafted by lawyers.’” Govan v. Campbell, 289 F. Supp. 2d 289, 295 (N.D.N.Y. 2007) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)) (additional citations omitted). The Second Circuit has held that courts are obligated to “make reasonable allowances to protect pro se litigants” from inadvertently forfeiting legal rights merely because they lack a legal education. Id. (quoting Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir. 1983)). That said, “even a pro se party’s objections to a Report and Recommendation must be specific and clearly aimed at particular findings in the magistrate’s proposal . . . .” Machicote v. Ercole, No. 06-cv-13320, 2011 WL 3809920, at *2, (S.D.N.Y. Aug. 25, 2011) (citation omitted); accord Caldwell v. Petros, No. 22-cv-567, 2022 WL 16918287, at *1 (N.D.N.Y. Nov. 14, 2022). After appropriate review, “the

court may accept, reject or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). III. DISCUSSION The Court adopts those aspects of the Report-Recommendation to which no party has raised a specific objection, finding no clear error therein, including the background and the legal framework set forth in the Report-Recommendation, familiarity with which is presumed for purposes of this decision. Plaintiff is in custody following a conviction for manslaughter in the first degree. See https://nysdoccslookup.doccs.ny.gov/ (site last visited on July 1, 2025).2 Construed liberally, the Complaint asserts that certain posts on the “Justice for Kristine” Facebook page reveal that a District Attorney involved in Plaintiff’s case had improper contact with a potential witness and the public during his prosecution. See Dkt. No. 1; Dkt. No. 10 at 3. Facebook is the only Defendant

listed in the Complaint, and Plaintiff lists “subpoena duces tecum” as the legal basis for his claims. Id. at 1. The Report-Recommendation recommends dismissal of the Complaint for failure to state a claim based on three findings. Dkt. No. 9. First, the Complaint improperly asserts that private actors violated Plaintiff’s constitutional rights without allegations of state action. Id. at 5-6 (citing in part Flagg v. Yonkers Sav. & Loan Ass’n, FA, 396 F.3d 178, 186 (2d Cir. 2005)). Second, portions of the Complaint seek to impose civil liability based on violations of criminal law. Id. at 6-7 (citing in part Linda R.S. v. Richard D., 410 U.S. 614, 619 (1973)). Third, to the extent the Complaint seeks to collaterally attack Plaintiff’s criminal conviction, it is improper. Id. at 7-8

(citing in part Heck v. Humphrey, 512 U.S. 477, 486-87 (1994)). In his objections, Plaintiff argues that the Report-Recommendation incorrectly interpreted the Complaint to assert causes of action against Facebook. Plaintiff instead asserts that he “never stated that Facebook (Meta) violated any of his rights” but that he “has stated that the STATE DA and one other violated his rights.” Dkt. No. 10 at 2. He argues that the documents he seeks “would prove malicious intent” and “would prove witness tampering and obstruction of justice.” Id. He seeks the Facebook documents to prove “prosecutor misconduct . . .

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Marc Andrew Mario v. P & C Food Markets, Inc.
313 F.3d 758 (Second Circuit, 2002)
Govan v. Campbell
289 F. Supp. 2d 289 (N.D. New York, 2003)
Manganiello v. City of New York
612 F.3d 149 (Second Circuit, 2010)
Petersen v. Astrue
2 F. Supp. 3d 223 (N.D. New York, 2012)
Opperisano v. Jones
286 F. Supp. 3d 450 (E.D. New York, 2018)
Flagg v. Yonkers Savings & Loan Ass'n, FA
396 F.3d 178 (Second Circuit, 2005)
Linda R. S. v. Richard D.
410 U.S. 614 (Supreme Court, 1973)

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Bluebook (online)
Darling v. Facebook (META), Counsel Stack Legal Research, https://law.counselstack.com/opinion/darling-v-facebook-meta-nynd-2025.