Theophilus A. Knight, Jr. v. George A. Ocasio; Eric Gonzalez; New York City Department of Probation; John/Jane Does 1-10

District Court, S.D. New York·Decided July 15, 2026·No. 1:26-cv-04081·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THEOPHILUS A. KNIGHT, JR., Plaintiff, -against- 26-CV-4081 (LLS) GEORGE A. OCASIO; ERIC GONZALEZ; ORDER OF DISMISSAL NEW YORK CITY DEPARTMENT OF WITH LEAVE TO REPLEAD PROBATION; JOHN/JANE DOES 1-10, Defendants. LOUIS L. STANTON, United States District Judge: Plaintiff, who is appearing pro se, brings this action under 42 U.S.C. § 1983, alleging that Defendants violated his rights in connection with enforcement proceedings in the Bronx County Family Court. By order dated June 26, 2026, 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 leave to replead his claims in an amended complaint. The Court also denies Plaintiff’s motion for preliminary injunctive relief. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on 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); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also

1 Plaintiff filed this action without the $405.00 in fees or an IFP application. By order dated May 19, 2026, Chief Judge Laura Taylor Swain directed Plaintiff to cure this deficiency. (ECF 4.) Plaintiff filed an IFP application on June 18, 2026. dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. 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). 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 Plaintiff brings this action against Bronx County Family Court Support Magistrate George A. Ocasio; New York State Administrative Judge Eric Gonzalez; the New York City Department of Probation; and ten John/Jane Does. The following allegations are drawn from the complaint and Plaintiff’s motion for preliminary injunctive relief.2 Plaintiff is “involved” in proceedings before the Bronx County Family Court. (ECF 1, at 1.) He alleges that “[o]rders and

enforcement notices were allegedly delayed, incompletely served, or disputed as to proper notice.” (Id.) Plaintiff “pursed objections and appellate remedies in good faith,” but “[d]espite ongoing procedural disputes and appellate activity, enforcement escalated toward threatened warrant issuance.” (Id.) On an unspecified date, Plaintiff “received a Notice of Warrant stating that a warrant would be issued if Plaintiff failed to appear on June 11, 2026.” (ECF 2, at 1.) Plaintiff asserts that the warrant should not issue because “procedural disputes remain

2 The Court quotes from Plaintiff’s submissions verbatim. All spelling, grammar, and punctuation are as in the original documents unless noted otherwise. unresolved, including disputes related to service, notice, appellate review, and findings concerning [his] ability to pay.” (Id.) In the complaint, Plaintiff requests an injunction “preserving the status quo” and “preventing incarceration or warrant execution pending review.” (ECF 1, at 1.) In his motion for

preliminary injunctive relief, Plaintiff seeks an order “preventing warrant issuance, arrest, incarceration, or probation pending further review.” (ECF 2, at 2.) DISCUSSION A. Rule 8 Although pro se litigants enjoy the Court’s “special solicitude,” Ruotolo v. I.R.S., 28 F.3d 6, 8 (2d Cir. 1994) (per curiam), their pleadings 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. A complaint states a claim for relief if the claim is plausible. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). In reviewing a complaint for plausibility, the court accepts all well-pleaded factual allegations as true and draws all reasonable inferences in the pleader’s favor. Id. (citing

Twombly, 550 U.S. at 555). But the court need not accept “[t]hreadbare recitals of the elements of a cause of action,” which are essentially legal conclusions. Id. at 678 (citing Twombly, 550 U.S. at 555). As set forth in Iqbal: [T]he pleading standard Rule 8 announces does not require detailed factual allegations, but it demands more than an unadorned, the-defendant-unlawfully- harmed-me accusation. A pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do. Nor does a complaint suffice if it tenders naked assertions devoid of further factual enhancement. Id. (internal citations, quotation marks, and alteration omitted). 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. Rule 8 “does not demand that a complaint be a model of clarity or exhaustively present

the facts alleged,” but it does require, “at a minimum, that a complaint give each defendant fair notice of what the plaintiff’s claim is and the ground upon which it rests.” Atuahene v. City of Hartford, 10 F. App’x 33, 34 (2d Cir. 2001) (citation and quotation marks omitted). Here, Plaintiff’s complaint does not comply with Rule 8. Plaintiff alleges that, in the course of unspecified Family Court proceedings, unidentified judges issued orders and notices, which Plaintiff alleges were not properly served, and that an unidentified individual threatened to issue a warrant if Plaintiff failed to appear in court. Although Plaintiff asserts claims under the Due Process Clause, he alleges no facts suggesting that his due process rights have been violated. It is unclear to the Court, and would be unclear to any responding defendant, what viable claims and plausible supporting facts Plaintiff is alleging against which defendants. The Court therefore

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Theophilus A. Knight, Jr. v. George A. Ocasio; Eric Gonzalez; New York City Department of Probation; John/Jane Does 1-10 (Theophilus A. Knight, Jr. v. George A. Ocasio; Eric Gonzalez; New York City Department of Probation; John/Jane Does 1-10) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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