Waterman v. Nolan

CourtDistrict Court, S.D. New York
DecidedJune 22, 2023
Docket1:23-cv-04903
StatusUnknown

This text of Waterman v. Nolan (Waterman v. Nolan) 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
Waterman v. Nolan, (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ──────────────────────────────────── RORY WATERMAN, ET AL.,

Plaintiffs, 23-cv-4903 (JGK)

- against - MEMORANDUM OPINION AND ORDER KATHELEEN E. NOLAN, ET AL.,

Defendants. ──────────────────────────────────── JOHN G. KOELTL, District Judge:

The pro se plaintiffs, Rory Waterman and Marniqua Tompkins, brought this action against two defendants, Katheleen E. Nolan and Fourth Lenox Terrace Associates LLC (“Fourth Lenox”), alleging violations of their constitutional rights in connection with an eviction proceeding initiated against them. The plaintiffs seek relief for these alleged constitutional violations pursuant to 42 U.S.C. § 1983, and they assert related state-law claims for abuse of process and identity theft. The allegations in the plaintiffs’ pro se complaint, which the Court accepts as true and “construe[s] . . . liberally” for the purposes of this Opinion, Harris v. Mills, 572 F.3d 66, 71- 72 (2d Cir. 2009), indicate that the plaintiffs reside together in a New York City apartment. Fourth Lenox, a “business entit[y]” “registered” with the “Secretary of State of New York,” is the landlord. See Compl., ECF No. 1, ¶¶ 2, 55. The plaintiffs allege that Fourth Lenox receives federal housing funds, and that it is therefore subject to federal housing regulations. Id. ¶¶ 36-38.1 The plaintiffs allege that on January 6, 2023, Katheleen E.

Nolan, a “licensed attorney who practices law in . . . New York,” initiated a “special” “dispossessory proceeding[]” against the plaintiffs in the Civil Court of the City of New York, New York County, Housing Part. Id. ¶¶ 20, 26; see also id. ¶ 71 (listing a case index number in the format used for housing court). Nolan initiated this proceeding on behalf of Fourth Lenox. See id. ¶ 20. Later, on March 29, 2023, Nolan sent the plaintiffs additional “signed correspondence,” which stated that “[u]nless you remove from [the] premises on May 31, 2023, the date on which your term expires, your Landlord will commence summary proceedings to remove you therefrom for holding over after the expiration of your term.” Id. ¶ 47. The plaintiffs assert that these efforts to remove them

from the property are improper because, among other reasons, they are not “tenants” within the meaning of applicable law, and they have not received an allegedly required “due process hearing.” Id. ¶¶ 23-24, 31, 40-45. The plaintiffs, relying on 42 U.S.C. § 1983, seek damages and injunctive relief on the grounds that the “conduct of both

1 Unless otherwise noted, this Memorandum Opinion and Order omits all alterations, omissions, emphasis, quotation marks, and citations in quoted text. [d]efendants” in connection with this “dispossessory proceeding” deprived the plaintiffs of their due process rights. Id. ¶¶ 61-62. The plaintiffs also assert a state-law claim for abuse of process

based on the housing court proceeding, id. ¶¶ 63-69, as well as a state-law claim for identity theft, which appears to be based on Nolan’s use of the plaintiffs’ names and address in housing court filings, see id. ¶¶ 20, 71.2 Section 1983 provides, in relevant part, that any “person who, under color of any statute, ordinance, regulation, custom, or usage, of any State,” deprives an individual of “any rights, privileges or immunities secured by the Constitution” or federal law “shall be liable to the party injured.” 42 U.S.C. § 1983. Because “[t]he core purpose of § 1983 is to provide compensatory relief to those deprived of their federal rights by state actors,” a defendant may be held liable under the statute only where the

“actions alleged by the plaintiffs come within the definition of ‘under color of’ state law.” Kia P. v. McIntyre, 235 F.3d 749, 755 (2d Cir. 2000). This “under-color-of-state-law element of § 1983 excludes from its reach merely private conduct, no matter

2 The plaintiffs also appear to assert that the defendants used their personal information to open a financial “account” in the plaintiffs’ name without consent. See Compl. ¶ 71. However, the alleged “account [] number” referenced in the complaint is actually the case index number for the housing court proceeding. Id. how discriminatory or wrongful.” Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 50 (1999). A private entity or individual “may be considered a state

actor” for purposes of a § 1983 claim only “if [that private defendant’s] conduct is fairly attributable to the state.” Leeds v. Meltz, 85 F.3d 51, 54 (2d Cir. 1996). Thus, a § 1983 claim “may be proved by showing that a person acting under color of state law collaborated or conspired with a private person to deprive the plaintiff of a constitutional right.” Singer v. Fulton Cnty. Sheriff, 63 F.3d 110, 119 (2d Cir. 1995). Private conduct may also be considered state action where “[t]he State has so far insinuated itself into a position of interdependence with [the private party] that it must be recognized as a joint participant in the challenged activity.” Burton v. Wilmington Parking Auth., 365 U.S. 715, 725 (1961). “[T]he inquiry must be

whether there is a sufficiently close nexus between the State and the challenged action . . . so that the action . . . may be fairly treated as that of the State itself.” Jackson v. Metro. Edison Co., 419 U.S. 345, 351 (1974). Although it appears that the plaintiffs in this case seek to challenge a state eviction proceeding, their complaint makes clear that both defendants are private actors: Fourth Lenox is a private landlord, and Nolan is a private attorney. Moreover, the complaint lacks allegations sufficient to support an inference that the alleged misconduct of these private actors is “fairly attributable to the state.” Leeds, 85 F.3d at 54. The complaint contains no allegations that either private defendant “collaborated

or conspired” with a state actor to deprive the plaintiffs of their constitutional rights. Singer, 63 F.3d at 119. Furthermore, the plaintiffs have not plausibly alleged a sufficiently close nexus between the private defendants’ alleged misconduct and the state. The only allegations suggesting a link between the defendants and a government actor are that (1) Fourth Lenox is registered to do business in New York state, (2) Nolan has a state-issued license to practice law, and (3) Fourth Lenox receives federal financial assistance and is therefore subject to federal housing policies and regulations. But a state-issued license or state business registration is not an adequate basis for finding that a private defendant engaged in conduct as a state

actor. See, e.g., Hopkins v. Comptroller, No. 22-cv-4505, 2022 WL 2954350, at *3 (S.D.N.Y. July 26, 2022) (“It is well settled that private attorneys do not act under color of state law and are not state actors simply by virtue of their state-issued licenses to practice law.”); cf. Schlein v. Milford Hosp., Inc., 561 F.2d 427, 428-29 (2d Cir.

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Related

Burton v. Wilmington Parking Authority
365 U.S. 715 (Supreme Court, 1961)
Jackson v. Metropolitan Edison Co.
419 U.S. 345 (Supreme Court, 1974)
Chavis v. Chappius
618 F.3d 162 (Second Circuit, 2010)
Allen P. Schlein, M.D. v. The Milford Hospital, Inc.
561 F.2d 427 (Second Circuit, 1977)
Gonzalez v. Micelli Chocolate Mold Co.
514 F. App'x 11 (Second Circuit, 2013)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Kia P. v. McIntyre
235 F.3d 749 (Second Circuit, 2000)

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Waterman v. Nolan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waterman-v-nolan-nysd-2023.