Mavins v. Sanchez

CourtDistrict Court, E.D. New York
DecidedJune 6, 2025
Docket2:24-cv-08124
StatusUnknown

This text of Mavins v. Sanchez (Mavins v. Sanchez) 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
Mavins v. Sanchez, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -----------------------------------------------------------------X BETTY M. MAVINS,

Plaintiff, MEMORANDUM v. AND ORDER 24-CV-08124-SJB-ST

UNITED STATES POSTAL SERVICE, et al.,

Defendants. -----------------------------------------------------------------X BULSARA, United States District Judge: Before the Court is the Amended Complaint filed pro se by Betty M. Mavins (“Mavins”) and her renewed motion to proceed in forma pauperis (“IFP”). (Am. Compl. dated Dec. 30, 2024 (“Am. Compl.”), Dkt. No. 8; Mot. to Proceed IFP dated Dec. 9, 2024 (“IFP Mot.”), Dkt. No. 7). The Court finds that the financial information reported by Mavins now qualifies her to commence this action without prepayment of the filing fee. Accordingly, the renewed IFP motion is granted. However, the Amended Complaint is dismissed without prejudice for lack of subject matter jurisdiction. Mavins is granted 30 days—until July 7, 2025—to file an amended complaint. FACTUAL BACKGROUND AND PROCEDURAL HISTORY Mavins commenced this action on November 7, 2024, and named two individuals as defendants, Jamaris Sanchez (“Sanchez”) and “Charlene.”1 (Compl.

1 Sanchez is alleged to be a “letter carrier” and Charlene a supervisor at the Hempstead Post Office located in Hempstead, New York. (Compl. at 2). dated Nov. 7, 2024 (“Compl.”), Dkt. No. 1 at 2). By Order dated November 26, 2024, District Judge Joan M. Azrack denied her motion to proceed IFP without prejudice and with leave to renew. (See Order dated Nov. 26, 2024, Dkt. No. 4; Appl. to Proceed IFP

dated Nov. 7, 2024, Dkt. No. 2). On December 9, 2024, Mavins filed a renewed IFP motion, and on December 30, 2024, an Amended Complaint. (IFP Mot.; Am. Compl.). On January 17, 2025, this case was reassigned to the undersigned. The Amended Complaint names as defendants Sanchez and Charlene, and also adds the United States Postal Service (“USPS” and collectively, “Defendants”). (See Am. Compl. at 1). Mavins alleges that for the past two years, Sanchez and Charlene

have engaged in mail theft and delivery delay tactics, including stealing a birthday card with cash, delaying her mail by several months, and stopping her first class mail entirely—including mail from her bank, landlord, and Medicaid/Medicare. (Id. ¶¶ 2–4, and at 3–4). Mavins alleges that as a result, she has suffered financial harm, fines for delayed utility payments, and physical effects such as hypertension. (Id. ¶¶ 2, 4). Mavins seeks $5,000,000. (Id. at 1). DISCUSSION

A complaint must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The determination of whether a party has alleged a plausible claim is “a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679. A pro se plaintiff’s pleadings are held “to less stringent standards than formal pleadings drafted by lawyers[.]” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)); see also Harris v. Mills, 572 F.3d 66, 72

(2d Cir. 2009) (noting that “[e]ven after Twombly,” courts “remain obligated to construe a pro se complaint liberally”). “Where, as here, the complaint was filed pro se, it must be construed liberally with ‘special solicitude’ and interpreted to raise the strongest claims that it suggests.” Hogan v. Fischer, 738 F.3d 509, 515 (2d Cir. 2013) (quoting Hill v. Curcione, 657 F.3d 116, 122 (2d Cir. 2011)); Bertin v. United States, 478 F.3d 489, 491 (2d Cir. 2007) (“We liberally construe pleadings and briefs submitted by pro se litigants . . .

‘to raise the strongest arguments they suggest’” (quoting Burgos v. Hopkins, 14 F.3d 787, 790 (2d Cir. 1994)). “This is particularly so when the pro se plaintiff alleges that [his] civil rights have been violated.” Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008). “Before deciding any case on the merits, a district court must determine that it has subject matter jurisdiction over the matter,” Humphrey v. Syracuse Police Dep’t, 758 F. App’x 205, 205–06 (2d Cir. 2019), including cases brought by IFP complainants. E.g.,

Chestnut v. Wells Fargo Bank, N.A., No. 11-CV-5369, 2012 WL 1657362 at *2, *5 (E.D.N.Y. May 7, 2012) (dismissing claims under IFP Statute where court lacked subject matter jurisdiction). Thus, “[n]otwithstanding the liberal pleading standard afforded pro se litigants, federal courts are courts of limited jurisdiction and may not preside over cases if subject matter jurisdiction is lacking.” Id. at *3 (citing Lyndonville Sav. Bank & Tr. Co. v. Lussier, 211 F.3d 697, 700–01 (2d Cir. 2000)). “[F]ailure of subject matter jurisdiction . . . may be raised . . . by the court sua sponte.” Lyndonville, 211 F.3d at 700. The Federal Rules of Civil Procedure mandate that “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3).

Relatedly, it is well established that “[t]he doctrine of sovereign immunity bars federal courts from hearing all suits for monetary damages against the federal government, including federal agencies . . . unless sovereign immunity has been waived.” Humphrey v. Internal Revenue Serv., No. 22-CV-1052, 2022 WL 17728194, at *1 (2d Cir. Dec. 16, 2022) (citing United States v. Mitchell, 445 U.S. 535, 538 (1980)). The doctrine is jurisdictional, and where present, the Court must dismiss the claim barred

by sovereign immunity pursuant to Rule 12(b)(1). See Wake v. United States, 89 F.3d 53, 57 (2d Cir. 1996). Suits against the USPS and its employees are barred by sovereign immunity, unless an exception applies. See Dolan v. USPS, 546 U.S. 481, 484 (2006). The well- known exception is the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 1346(b), 2671– 2680, which provides for a waiver of sovereign immunity for injuries arising from the tortious conduct of federal officers or agents “acting within the scope of his office or

employment[.]” 28 U.S.C. § 1346(b)(1). But there are exceptions to the exception, and as relevant here, the “postal matter exception” restores immunity for “[a]ny claim arising out of the loss, miscarriage, or negligent transmission of letters or postal matter.” 28 U.S.C. § 2680

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
United States v. Mitchell
445 U.S. 535 (Supreme Court, 1980)
Dolan v. United States Postal Service
546 U.S. 481 (Supreme Court, 2006)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Lenore S. Raila, Whitton A. Raila v. United States
355 F.3d 118 (Second Circuit, 2004)
Shomo v. City of New York
579 F.3d 176 (Second Circuit, 2009)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Sealed v. Sealed 1
537 F.3d 185 (Second Circuit, 2008)
Hogan v. Fischer
738 F.3d 509 (Second Circuit, 2013)

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Mavins v. Sanchez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mavins-v-sanchez-nyed-2025.