Lim v. New York State Board of Law Examiners

CourtDistrict Court, N.D. California
DecidedMay 7, 2025
Docket4:25-cv-02660
StatusUnknown

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

Bluebook
Lim v. New York State Board of Law Examiners, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 KHOR CHIN LIM, Case No. 25-cv-02660-LJC

8 Plaintiff, ORDER GRANTING APPLICATION 9 v. TO PROCEED IN FORMA PAUPERIS AND DENYING WITHOUT 10 NEW YORK STATE BOARD OF LAW PREJUDICE MOTION FOR SERVICE EXAMINERS, et al., OF PROCESS 11 Defendants. ORDER TO SHOW CAUSE WHY 12 CASE SHOULD NOT BE DISMISSED

13 Re: Dkt. Nos. 1, 3, 6

14 15 A. Application to Proceed in Forma Pauperis 16 Plaintiff Khor Chin Lim, pro se, has applied to proceed in forma pauperis. ECF No. 3. 17 Sufficient cause having been shown, that application is GRANTED. 18 B. Sufficiency of Complaint 19 1. Legal Standards 20 A district court must dismiss a case filed without the payment of the filing fee whenever it 21 determines that the action “(i) is frivolous or malicious; (ii) fails to state a claim on which relief 22 may be granted; or (iii) seeks monetary relief against a defendant who is immune from such 23 relief.” 28 U.S.C. § 1915(e)(2)(B)(i)–(iii). If the Court dismisses a case pursuant to 24 § 1915(e)(2)(B), the plaintiff may still file the same complaint by paying the filing fee. Such 25 dismissal is not on the merits, but rather an exercise of the court’s discretion under the statute 26 governing cases filed in forma pauperis. Denton v. Hernandez, 504 U.S. 25, 32 (1992). Courts 27 conducting this review assess whether the complaint “lacks an arguable basis either in law or in 1 Under § 1915(e)(2)(B)(i), frivolousness “embraces not only the inarguable legal 2 conclusion, but also the fanciful factual allegation.” Id. A complaint may be dismissed as 3 “factually frivolous only if the facts alleged are clearly baseless, a category encompassing 4 allegations that are fanciful, fantastic, and delusional.” Denton, 504 U.S. at 32–33. 5 A court must dismiss a complaint for failure to state a claim under § 1915(e)(2)(B)(ii) 6 where it is based solely on conclusory statements or naked assertions without any factual basis, 7 lacking sufficient factual allegations to render the claims asserted plausible. See Ashcroft v. Iqbal, 8 556 U.S. 662, 677–78 (2009). 9 Complaints that are “highly repetitious, or confused, or consisted of incomprehensible 10 rambling” also violate the federal pleading standard. Cafasso, United States ex rel. v. Gen. 11 Dynamics C4 Sys., Inc., 637 F.3d 1047, 1059 (9th Cir. 2011). Rule 8 of the Federal Rules of Civil 12 Procedure provides that a complaint must present “a short and plain statement of the claim 13 showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A court may dismiss an 14 overly convoluted complaint for its failure to meet that requirement. McHenry v. Renne, 84 F.3d 15 1172, 1179 (9th Cir. 1996) (“Prolix, confusing complaints such as the ones plaintiffs filed in this 16 case impose unfair burdens on litigants and judges.”) District courts have held dismissed 17 complaints that fail to state a “short and plaint statement” standard as frivolous and for failure to 18 state a claim on which relief may be granted under 28 U.S.C. § 1915(e)(2)(B). E.g., Franklin v. 19 Newsom, No. 3:21-cv-01645-GPC-BGS, 2021 WL 5827117, at *4–5 (S.D. Cal. Dec. 7, 2021); 20 Washington v. Deleon, No. 19-cv-02271-JCS, 2019 WL 11691426, at *6 (N.D. Cal. May 7, 2019), 21 recommendation adopted, 2019 WL 11691197 (N.D. Cal. May 28, 2019). 22 The Federal Rules also place limits on a plaintiff’s ability to name multiple defendants in 23 the same lawsuit. Multiple defendants may be joined in a single action only where:

24 (A) any right to relief is asserted against them jointly, severally, or in the alternative with respect to or arising out of the same transaction, 25 occurrence, or series of transactions or occurrences; and

26 (B) any question of law or fact common to all defendants will arise in the action. 27 Fed. R. Civ. P. 20(a)(2). 1 At least one decision from this district has found a complaint to be frivolous under 2 § 1915(e)(2)(B) based on “extreme failure to comply with the rules for joinder,” where a plaintiff 3 sued a wide range of defendants over conduct spanning many states and years and offered no more 4 than conclusory assertions of “some conspiracy or concerted action among all ninety defendants.” 5 Cooney v. City of San Diego, No. 18-cv-01860-JCS, 2018 WL 11249355, at *3 (N.D. Cal. June 6 28, 2018), recommendation found moot, 2018 WL 11249356 (N.D. Cal. July 17, 2018) (finding 7 review under § 1915(e)(2)(B) to be moot after the plaintiff paid the filing fee). 8 Complaints filed without counsel must “be liberally construed” and “held to less stringent 9 standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) 10 (per curiam). Courts ordinarily must give pro se plaintiffs leave to “amend their complaint unless 11 it is absolutely clear that the deficiencies of the complaint could not be cured by amendment.” 12 Franklin v. Murphy, 745 F.2d 1221, 1235 n.9 (9th Cir. 1984). 13 2. Plaintiff’s Complaint Appears Frivolous 14 As demonstrated by the attachments to his present Complaint (ECF No. 1), Plaintiff has 15 previously filed many other cases in many other courts. He does not appear to have met with 16 success. The Eastern District of Wisconsin found an apparently similar complaint that Plaintiff 17 filed in 2021 to be frivolous, and noted that the Western District of Wisconsin reached the same 18 conclusion in several previous cases:

19 The complaint is largely incomprehensible but does make out a general laundry list of grievances against each defendant for wrongs 20 ranging from a bad grade on an economics quiz in 1996, ECF No. 1 ¶ 34, to a massive conspiracy by several jurists, police officers, 21 prosecutors, public defenders, the CEO of JP Morgan Chase, and President Barack Obama to wrongly convict Lim of possession of 22 Molotov cocktails and prevent his appeal, ECF No. 1 ¶ 33. The list goes on, and there are several more allegations, each as fantastical as 23 the next. Furthermore, Lim has a history of filing frivolous lawsuits. E.g., Lim v. City of Chicago, No. 13-CV-347-BBC, 2013 WL 24 3967889, at *1 (W.D. Wis. July 31, 2013) (“[Lim] is restricted from filing new cases without paying the full filing fee because he has filed 25 at least three cases in this court that have been deemed frivolous.”). 26 Lim v. JP Morgan Chase Bank NA, No. 21-CV-1277-SCD, 2021 WL 11586133, at *1 (E.D. Wis. 27 Nov. 16, 2021), recommendation adopted, 2021 WL 11586132 (E.D. Wis. Dec. 1, 2021). 1 One might reasonably wonder what this action, where the first defendant to appear in the 2 caption is the New York State Board of Law Examiners, has to do with a prior case against former 3 President Barack Obama and JP Morgan Chase CEO Jamie Dimon.

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Related

Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ortiz-Pinero v. Rivera-Arroyo
84 F.3d 7 (First Circuit, 1996)
Cafasso v. General Dynamics C4 Systems, Inc.
637 F.3d 1047 (Ninth Circuit, 2011)
Harry Franklin v. Ms. Murphy and Hoyt Cupp
745 F.2d 1221 (Ninth Circuit, 1984)

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Bluebook (online)
Lim v. New York State Board of Law Examiners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lim-v-new-york-state-board-of-law-examiners-cand-2025.