Smalls v. Fuchs

CourtDistrict Court, S.D. New York
DecidedMarch 13, 2025
Docket1:25-cv-00776
StatusUnknown

This text of Smalls v. Fuchs (Smalls v. Fuchs) 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
Smalls v. Fuchs, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK AARON DESMOND SMALLS, Plaintiff, 25-CV-0776 (LTS) -against- ORDER OF DISMISSAL ALYSSA FUCH; COHEN AND FITCH, WITH LEAVE TO REPLEAD Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action invoking 42 U.S.C. § 1983. He sues an attorney and her law firm for alleged legal malpractice representing him in his civil case against police officers for excessive force. This complaint was originally filed in the United States District Court for the Eastern District of New York, which transferred it to this court. By order dated January 28, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis (IFP), that is, without prepayment of fees. For the reasons set forth in this order, the Court dismisses the action for lack of subject matter jurisdiction, with 30 days’ leave to replead. 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 in forma pauperis complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim 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.

BACKGROUND The following facts are drawn from the complaint.1 In December 2021, police officers assaulted Plaintiff. (ECF 1 at 4.) In February 2022, Alyssa Fuch of the law firm Cohen and Fitch was “assigned” to represent Plaintiff.2 In March 2023, Plaintiff was “partially paid $22,000 . . . .” (Id. at 3.) Non-party “Brittoney Johnson,” whose relationship to the proceedings is unclear, allegedly informed Plaintiff in June 2023, that Fuch “kept [Plaintiff’s] lawsuit running, lied to [him] about the amount she received [and] called [Plaintiff] a dummy.” (Id.) Plaintiff contacted Fuch to obtain documents and evidence from the civil case, including video evidence of the police brutality and documents from the New York City Comptroller. Fuch told Plaintiff that she

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. 2 Plaintiff had a pending civil rights action, Smalls v. 24th Precinct, No. 22-CV-03205 (GHW), in which Fuchs entered a notice of appearance on Plaintiff’s behalf (ECF 10). The district court then held that the action had already been dismissed without prejudice, pursuant to Plaintiff’s notice of voluntary dismissal (ECF 12), and directed that the amended complaint be stricken (ECF 17). had “destroyed everything.” (Id. at 4.) Plaintiff describes Fuch as “a trans-op Jewish white woman becoming a man.” (Id.) Plaintiff then filed a notice of claim with non-party New York City Comptroller Brad Lander. (Id.) Months passed and finally Olivia Lam “disallowed” the claim. Plaintiff “assumes”

that Lander and Lam conspired against him “for racial, personal, [and] religious reasons.” (Id.) Plaintiff seeks access to video and documents obtained by the law firm Cohen and Fitch, reopening of his police brutality case, and $2 million. He sues Fuch and Cohen and Fitch, pursuant to 42 U.S.C. § 1983. DISCUSSION A. Lack of Subject Matter Jurisdiction The subject matter jurisdiction of the federal district courts is limited and is set forth generally in 28 U.S.C. §§ 1331 and 1332. Under these statutes, federal jurisdiction is available only when a “federal question” is presented or when plaintiff and defendant are citizens of different states and the amount in controversy exceeds the sum or value of $75,000. “‘[I]t is common ground that in our federal system of limited jurisdiction any party or the court sua

sponte, at any stage of the proceedings, may raise the question of whether the court has subject matter jurisdiction.’” United Food & Com. Workers Union, Loc. 919, AFL-CIO v. CenterMark Prop. Meriden Square, Inc., 30 F.3d 298, 301 (2d Cir. 1994) (quoting Manway Constr. Co., Inc. v. Hous. Auth. of the City of Hartford, 711 F.2d 501, 503 (2d Cir. 1983)); see Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative . . . .”). Federal Question Jurisdiction To support federal question jurisdiction, a plaintiff’s claims must arise “under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. A case arises under federal law if the complaint “establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal

law.” Bay Shore Union Free Sch. Dist. v. Kain, 485 F.3d 730, 734-35 (2d Cir. 2007) (quoting Empire Healthchoice Assur., Inc. v. McVeigh, 547 U.S. 677, 690 (2006)). Merely invoking federal jurisdiction, without pleading any facts demonstrating a federal law claim, does not create federal subject matter jurisdiction. See Nowak v. Ironworkers Loc.

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Bluebook (online)
Smalls v. Fuchs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smalls-v-fuchs-nysd-2025.