Valerie Flores v. Liberty Mutual Insurance and Enterprise Rent-A-Car a/k/a Enterprise Holdings

CourtDistrict Court, N.D. New York
DecidedApril 30, 2026
Docket1:25-cv-01730
StatusUnknown

This text of Valerie Flores v. Liberty Mutual Insurance and Enterprise Rent-A-Car a/k/a Enterprise Holdings (Valerie Flores v. Liberty Mutual Insurance and Enterprise Rent-A-Car a/k/a Enterprise Holdings) 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
Valerie Flores v. Liberty Mutual Insurance and Enterprise Rent-A-Car a/k/a Enterprise Holdings, (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

VALERIE FLORES, Plaintiff, V. No. 1:25-CV-1730 LIBERTY MUTUAL INSURANCE and (AMN/PJE) ENTERPRISE RENT-A-CAR a/k/a ENTERPRISE HOLDINGS, Defendants.

APPEARANCES: Valerie Flores P.O. Box 1110 ACP 5749 Albany, New York 12201 _| Plaintiff pro se PAUL J. EVANGELISTA U.S. MAGISTRATE JUDGE REPORT-RECOMMENDATION AND ORDER’ Pro se plaintiff Valerie Flores (“Plaintiff’) commenced this action on December 10, 2025, with the filing of a complaint. See Dkt. No. 1.2 Plaintiff has not paid the filing fee and seeks leave to proceed in forma pauperis (“IFP”). See Dkt. No. 2.5 The m undersigned has reviewed plaintiff's IFP application and determines that she financially

matter was referred to the undersigned for Report-Recommendation and Order pursuant to 28 U.S.C. § 636(b) and N.D.N.Y. L.R. 72.3(c). ? On February 4, 2026, this Court implemented a prefiling injunction stating that plaintiff may not commence any new actions in this District without proper permission of the chief judge, as well as a revocation of her MFT privileges. See 1:26-pf-0001 (BKS), /n re Valerie Flores. As this action was commenced before the entry of that prefiling injunction, it does not apply to this case. 3 Plaintiff also filed a motion for appointment of counsel. See Dkt. No. 3.

qualifies to proceed IFP.* Plaintiff generally alleges that defendants Enterprise Rent-A- Car stole her personal belongings out of a rental car and charged her for the rental of the vehicle, despite her claim that her automobile insurance company, defendant Liberty Mutual Insurance, was required to pay for the rental, which she alleges they have not done. See Dkt. No. 1. For the reasons set forth below, it is recommended that plaintiff's complaint be dismissed without prejudice and without opportunity to amend |. Initial Review A. Legal Standards 28 U.S.C. § 1915 directs that, when a plaintiff seeks to proceed IFP, “the court shall dismiss the case at any time if the court determines that .. . the action or appeal (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks _,.|Monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B).° “Thus, it is a court’s responsibility to determine that a plaintiff may properly maintain his complaint before permitting him to proceed further with his action.” Praileau v. Fischer, 930 F. Supp. 2d 383, 394 (N.D.N.Y. 2013). Where, as here, the plaintiff proceeds pro se, “the court must construe his submissions liberally and interpret them to raise the strongest arguments that they m| Suggest.” Kirkland v. Cablevision Sys., 760 F.3d 223, 224 (2d Cir. 2014) (per curiam) (internal quotation marks and citation omitted). As the Second Circuit stated, [tIhere are many cases in which we have said that a pro se litigant is entitled to special solicitude, that a pro se litigant’s submissions must be

4 Plaintiff is advised that although she has been granted IFP status, she is still required to pay any fees and costs that could be incurred in this matter. 5 These requirements apply equally to non-prisoner pro se litigants. See N.D.N.Y. L.R. 72.3(d) (“Unless the Court orders otherwise, any civil action that a non-prisoner pro se litigant commences shall be referred to a Magistrate Judge for the purpose of review under 28 U.S.C. §1915(e)(2) and 28 U.S.C. §1915A when an application to proceed in forma pauperis is filed.”).

construed liberally, and that such submissions must be read to raise the strongest arguments that they suggest. At the same time, our cases have also indicated that we cannot read into pro se submissions claims that are not consistent with the pro se litigant’s allegations, or arguments that the submissions themselves do not suggest, that we should not excuse frivolous or vexatious filings by pro se litigants, and that pro se status does not exempt a party from compliance with relevant rules of procedural and substantive law... . Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 477 (2d Cir. 2006) (internal quotation marks, citations, and footnote omitted); see also Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008) (“On occasions too numerous to count, we have reminded district courts that when [a] plaintiff proceeds pro se, . . . a court is obligated to construe his pleadings liberally.”) (internal quotation marks and citations omitted). Thus, the Court is not required to accept unsupported allegations that are devoid of sufficient facts or claims. Although detailed allegations are not required at the pleading stage, the complaint must still include enough facts to provide the defendants with notice of the claims against them and the grounds upon which these claims are based. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); see also Bell Atlantic v. Twombly, 550 U.S. 544, 555-56 (2007). Ultimately, the plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570; see Iqbal, 556 U.S. at 678 (“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the tt reasonable inference that the defendant is liable for the misconduct alleged.”). “The [Second Circuit]’s ‘special solicitude’ for pro se pleadings has its limits, because pro se pleadings still must comply with . . . the Federal Rules of Civil Procedure.”® Kastner v. Tri State Eye, No. 19-CV-10668 (CM), 2019 WL 6841952, at *2 (S.D.N.Y. Dec.

® Hereafter, “Fed. R. Civ. P.”

13, 2019) (quoting Ruotolo v. IRS, 28 F.3d 6, 8 (2d Cir. 1994)).”? Specifically, Rule 8 provides that a pleading which sets forth a claim for relief shall contain, among other things, “a short and plain statement of the claim showing that the pleader is entitled to relief.” Feb. R. Civ. P. 8(a)(2). Further, notwithstanding 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. Uzoefune v. Am. Auto Shield, LLC, No. 18CV03441, 2018 WL 5624149, at *2 (E.D.N.Y. Oct. 30, 2018) (citing Lyndonville Sav. Bank & Trust Co. v. Lussier, 211 F.3d 697, 700-01 (2d Cir. 2000)).® Il. Discussion A. Plaintiff's Complaint® Affording Plaintiff special solicitude, she alleges that defendant corporation .| Enterprise Rent-A-Car stole her personal belongings out of a rental car and charged her for the rental of the vehicle. See Compl. She further alleges that Liberty Mutual Insurance failed in its duty to reimburse her for the cost of the rental. See Dkt. No. 1 at 4.

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Bell Atlantic Corp. v. Twombly
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Sealed v. Sealed 1
537 F.3d 185 (Second Circuit, 2008)
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Praileau v. Fischer
930 F. Supp. 2d 383 (N.D. New York, 2013)

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Valerie Flores v. Liberty Mutual Insurance and Enterprise Rent-A-Car a/k/a Enterprise Holdings, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valerie-flores-v-liberty-mutual-insurance-and-enterprise-rent-a-car-aka-nynd-2026.