Falls v. Keenan

CourtDistrict Court, S.D. New York
DecidedAugust 28, 2025
Docket1:25-cv-05874
StatusUnknown

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

Bluebook
Falls v. Keenan, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK RAIQUAN K. FALLS, Plaintiff, -against- 25-CV-5874 (LLS) EDWARD EMMET KEENAN, KEENAN AND ORDER OF DISMISSAL BHATIA, LLC; SCOTT A. KORENBAUM, WITH LEAVE TO REPLEAD LAW OFFICES OF SCOTT A. KORENBAUM, Defendants. LOUIS L. STANTON, United States District Judge: Plaintiff, who currently is incarcerated at Green Haven Correctional Facility, brings this action, pro se, under the court’s federal question jurisdiction, alleging that Defendants violated his rights in the course of representing him in a civil matter in this court. Named as Defendants are Edward Emmett Keenan of the law firm Keenan and Bhatia, LLC, and Scott A Korenbaum of the Law Offices of Scott A. Korenbaum. By order dated August 12, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees.1 For the reasons set forth below, the Court dismisses the complaint, but grants Plaintiff 30 days’ leave to replead his claims in an amended complaint. STANDARD OF REVIEW The Prison Litigation Reform Act requires that federal courts screen complaints brought by prisoners who seek relief against a governmental entity or an officer or employee of a governmental entity. See 28 U.S.C. § 1915A(a). The Court must dismiss a prisoner’s IFP

complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim

1 Prisoners are not exempt from paying the full filing fee even when they have been granted permission to proceed IFP. See 28 U.S.C. § 1915(b)(1). upon 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), 1915A(b); see Abbas v. Dixon, 480 F.3d 636, 639 (2d Cir. 2007). The Court must also dismiss a complaint if the Court lacks subject matter jurisdiction. See Fed. R. Civ. P. 12(h)(3).

While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief. Rule 8 requires a complaint to include enough facts to state a claim for relief “that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially

plausible if the plaintiff pleads enough factual detail to allow the Court to draw the inference that the defendant is liable for the alleged misconduct. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. After separating legal conclusions from well-pleaded factual allegations, the Court must determine whether those facts make it plausible – not merely possible – that the pleader is entitled to relief. Id. BACKGROUND The following facts are drawn from the complaint.2 Plaintiff Raiquan Falls is also the plaintiff in another civil action currently pending in this court, Falls v. Pitt, No. 16-CV-8863 (KMK) (AEK) (S.D.N.Y.). The court in that action granted Plaintiff’s motion to request pro bono counsel and Defendant Edward Emmett Keenan volunteered to represent Plaintiff for the

purposes of a jury trial. The case was set to proceed to trial “sometime in 2024.” (ECF 1, at 2.) Plaintiff was later informed that Defendant Scott A. Korenbaum was assigned to assist Keenan. Defendants advised Plaintiff that the trial was scheduled to begin in August 2024, but it was postponed several times due to Judge Karas’s trial schedule. Plaintiff alleges that he and Defendants disagreed on several aspects of legal strategy in the case.3 Plaintiff asserts that Defendants’ main objective was to convince him to settle the case so they could “receive attorney fees or other financial benefit.” (Id. at 4.) After Plaintiff rejected several of the defendants’ settlement offers – communicated to him through the Defendants in this action – Defendants informed Plaintiff that they would be filing a motion to relieve themselves as Plaintiff’s attorneys in that action. Plaintiff asserts that he has a right to a trial and

that Defendants were “punish[ing]” him for exercising that right by “excessively prolo[n]ging of the trial” and communicating the defendants’ settlement offers. (Id. at 6.) Plaintiff attempts to assert federal constitutional claims and claims for legal malpractice. Plaintiff seeks money damages.

2 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. capitalization 3 The complaint includes details of Plaintiff’s discussion with Defendants that are arguably protected by attorney-client privilege. The Court has therefore asked the Clerk of Court to limit viewing of the complaint on the electronic docket to case participants only. For the same reason, the Court will not summarize here the details of Plaintiff’s disagreements with Defendants with respect to legal strategy. DISCUSSION A. Federal claims Although Plaintiff states that his federal constitutional claims arise under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), because he is not suing federal government employees, any constitutional claims would arise under 42 U.S.C. § 1983. A claim for relief under Section 1983 must allege facts showing that each defendant acted under the color of a state

“statute, ordinance, regulation, custom or usage.” 42 U.S.C. § 1983. Private parties therefore generally are not liable under the statute. Sykes v. Bank of Am., 723 F.3d 399, 406 (2d Cir. 2013) (citing Brentwood Acad. v. Tenn. Secondary Sch. Athletic Ass’n, 531 U.S. 288, 295 (2001)); see also Ciambriello v. Cnty. of Nassau, 292 F.3d 307, 323 (2d Cir.

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Bluebook (online)
Falls v. Keenan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falls-v-keenan-nysd-2025.