Sanders v. New York State

CourtDistrict Court, N.D. New York
DecidedSeptember 15, 2025
Docket5:24-cv-01432
StatusUnknown

This text of Sanders v. New York State (Sanders v. New York State) 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
Sanders v. New York State, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

THERESA A. SANDERS,

Plaintiff, 5:24-cv-1432 (ECC/TWD) v.

NEW YORK STATE,

Defendant.

Theresa A. Sanders, pro se Plaintiff Elizabeth Lombardi, Esq., for Defendant

Hon. Elizabeth C. Coombe, United States District Judge: MEMORANDUM-DECISION AND ORDER Plaintiff Theresa Sanders filed this action against Defendant New York State (the State) alleging violations of the Sixth and Fourteenth Amendments of the United States Constitution and Article 1 § 6 of the New York State Constitution. Dkt. No. 1. Presently before the Court is Defendant’s motion to dismiss pursuant to Rule 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. Dkt. No. 7. The motion is fully briefed. Dkt. Nos. 16, 19. I. FACTS1 On August 15, 2013, Plaintiff was indicted for eight counts of Larceny, eight counts of Falsification of Documents, two counts of Scheme to Defraud, and one count of Residential

1 These facts are drawn from the Complaint. The Court assumes the truth of, and draws reasonable inferences from, the well-pleaded factual allegations, see Lynch v. City of New York, 952 F.3d 67, 74–75 (2d Cir. 2020), but does not accept as true any legal conclusions, see Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Mortgage Fraud. Complaint (Compl.) ¶ 1 (p. 2), Dkt. No. 1.2 On January 12, 2015, Plaintiff pled guilty to one count of Residential Mortgage Fraud in the Second Degree and one count of Grand Larceny in the Second Degree. Id. at ¶ 81; Dkt. No. 1-2 at 32. Plaintiff was detained following her conviction. Compl. ¶¶ 2 (p. 2); 83. Plaintiff suffered serious harms to her health while she

was in the State’s custody. Id. at ¶¶ 83-85; 121. After Plaintiff was released from custody on December 15, 2015, Compl. ¶ 2 (p. 2), she requested the “evidence to justify her conviction,” and she received a thumb drive containing “hundreds of pages of evidence, both exculpatory and impeachment in nature that went directly to her 19-count indictment” that her appointed counsel had received as discovery, id. at ¶¶ 2-4 (p. 2-3). The trial court denied Plaintiff’s motion to vacate her criminal conviction pursuant to New York Criminal Procedure Law § 440.10, and the appellate courts affirmed that decision. Id. at ¶¶ 5-10. Plaintiff alleges that her ex-husband, the prosecution, the trial court, and her appointed counsel conspired to deny her a fair trial. Compl. ¶¶ 14-82. She also alleges that prosecutors withheld exculpatory evidence in violation of her Sixth Amendment rights, key witnesses falsified

relevant evidence, and her appointed counsel representation was unconstitutionally ineffective because he had a conflict of interest. Id. II. LEGAL STANDARD “A case is properly dismissed for lack of subject matter jurisdiction under Rule 12(b)(1) when the district court lacks the statutory or constitutional power to adjudicate it.” Forjone v. Dep’t of Motor Vehicles, 414 F. Supp. 3d 292, 297–98 (N.D.N.Y. 2019) (cleaned up). “In resolving a motion to dismiss under Rule 12(b)(1), the district court must take all uncontroverted

2 Citations to page numbers refer to pagination generated by the ECF system, unless otherwise noted. For any document with duplicative paragraph numbers, the ECF page for the citation is provided in parentheses. facts in the complaint . . . as true[ ] and draw all reasonable inferences in favor of the party asserting jurisdiction.” Tandon v. Captain’s Cove Marina of Bridgeport, Inc., 752 F.3d 239, 243 (2d Cir. 2014) (citation omitted). A court may also “refer to evidence outside the pleadings” and “take judicial notice of documents in the public record[.]” Krajisnik Soccer Club, Inc. v. Krajisnik

Football Club, Inc., No. 20-cv-1140 (LEK/TWD), 2021 WL 2142924, at *2 (N.D.N.Y. May 26, 2021) (citations omitted). “When a defendant seeks dismissal under Rule 12(b)(1) ‘as well as on other grounds, the court should consider the Rule 12(b)(1) challenge first since if it must dismiss the complaint for lack of subject matter jurisdiction, the accompanying defenses and objections become moot and do not need to be determined.’” Rosenberg v. LoanDepot, Inc., No. 21-cv-8719, 2023 WL 1866871, at *2 (S.D.N.Y. Feb. 9, 2023) (quoting Saint-Amour v. Richmond Org., Inc., 388 F. Supp. 3d 277, 286 (S.D.N.Y. 2019)); see also Kumpf v. N.Y. State United Tchrs., 642 F. Supp. 3d 294, 304–05 (N.D.N.Y. Nov. 22, 2022). “[W]here, as here, a plaintiff is proceeding pro se, the complaint must be considered under a more lenient standard than that accorded ‘formal pleadings drafted by lawyers.’” Harrison v.

New York, 95 F. Supp. 3d 293, 313 (E.D.N.Y. 2015) (citation omitted). The Complaint must also be construed liberally “to raise the strongest arguments that it suggests.” Costabile v. N.Y.C. Health & Hosps. Corp., 951 F.3d 77, 80 (2d Cir. 2020) (citation omitted). “Nonetheless, a pro se complaint must state a plausible claim for relief.” Darby v. Greenman, 14 F.4th 124, 128 (2d Cir. 2021) (quoting Walker v. Schult, 717 F.3d 119, 124 (2d Cir. 2013)). III. DISCUSSION Defendant argues, among other things, that the Complaint should be dismissed for lack of subject-matter jurisdiction based on the State’s sovereign immunity under the Eleventh Amendment. Dkt. No. 7-2 at 9-11. Plaintiff responds that “the Eleventh Amendment does not shield State actors from Federal Constitutional claims,” and it does not apply when the suit seeks only to “challenge the legality of the criminal proceeding brought against the Plaintiff” rather than seeking damages. Dkt. No. 16 at 16. “Without a State’s express waiver or an act by Congress under Section 5 of the Fourteenth

Amendment, the Eleventh Amendment bars federal courts from adjudicating claims against a State, as well as its agencies and agents.” 74 Pinehurst LLC v. New York, 59 F.4th 557, 570 (2d Cir. 2023), cert. denied, 218 L. Ed. 2d 66 (Feb. 20, 2024) (citing Will v. Michigan Dep’t of State Police, 491 U.S. 58, 66 (1989)). The “only exception exists for claims for prospective relief against state officials in their official capacities.” Id. (citing Ex parte Young, 209 U.S. 123, 159– 60 (1908)). The Ex parte Young exception applies only where “the complaint alleges an ongoing violation of federal law and seeks relief properly characterized as prospective,” Verizon Maryland, Inc. v. Pub. Serv. Comm’n of Maryland, 535 U.S. 635, 645 (2002), and plaintiff has “name[d] as defendant a state official rather than the state or a state agency,” Santiago v. N.Y. State Dep’t of Corr. Servs., 945 F.2d 25, 32 (2d Cir. 1991). Finally, the Eleventh Amendment protection applies

even to lawsuits filed by a state’s own citizens. PennEast Pipeline Co., LLC v. New Jersey, 594 U.S. 482, 499 (2021) (citing Hans v. Louisiana, 134 U.S. 1 (1890)). Claims arising under state law, including state constitutional claims, are precluded by state sovereign immunity. See Wang v. Off.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mamot v. Board of Regents
367 F. App'x 191 (Second Circuit, 2010)
Hans v. Louisiana
134 U.S. 1 (Supreme Court, 1890)
Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Maleng v. Cook
490 U.S. 488 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Raygor v. Regents of the University of Minnesota
534 U.S. 533 (Supreme Court, 2000)
United States v. Denedo
556 U.S. 904 (Supreme Court, 2009)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Walker v. Schult
717 F.3d 119 (Second Circuit, 2013)
Clinton v. Goldsmith
526 U.S. 529 (Supreme Court, 1999)
Winokur v. Office of Court Administration
190 F. Supp. 2d 444 (E.D. New York, 2002)
Feng Li v. Lorenzo
712 F. App'x 21 (Second Circuit, 2017)
Harrison v. New York
95 F. Supp. 3d 293 (E.D. New York, 2015)
Saint-Amour v. Richmond Org., Inc.
388 F. Supp. 3d 277 (S.D. Illinois, 2019)
Tandon v. Captain's Cove Marina of Bridgeport, Inc.
752 F.3d 239 (Second Circuit, 2014)
Gasparik v. Stony Brook University
296 F. App'x 151 (Second Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Sanders v. New York State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanders-v-new-york-state-nynd-2025.