In this action the United States Court of Appeals, Second Circuit, affirmed the judgement of a federal district court in three appeals brought by the Petitioner and being considered in tandem.
The federal district court had dismissed the Petitioner's claims for a variety of procedural errors or omissions including the Petitioner's failure to serve certain Defendants and Petitioner's failure to specify what relief Petitioner was seeking.
The federal district court granted the State Defendants' motion to dismiss Petitioner's claims as the State, as a Defendant:
1. Was entitled to state sovereign immunity "as recognized by the Eleventh Amendment";
2. That certain named Defendants were entitled absolute legislative immunity;
3. That Petitioner had "otherwise failed to state a claim";
4. That certain of Petitioner's complaints were barred by res judicata and collateral estoppel; and
5. That the district court lacked subject matter jurisdiction.
The Circuit Court noted although a "complaint must be construed liberally, with all factual allegations accepted as true, and all reasonable inferences drawn in the [Petitioner’s] favor", opined that a complaint’s '[f]actual allegations must be enough to raise a right to relief above the speculative level and contain more than a formulaic recitation of the elements of a cause of action,”
In addition, the Circuit Court observed "It has long been settled that state sovereign immunity precludes not only actions in which a State is actually named as the defendant, but also certain actions against state agents and state instrumentalities" and “generally bars suits in federal court by private individuals against non-consenting states.
Noting that “a plaintiff may sue a state official acting in his official capacity— notwithstanding the Eleventh Amendment—for prospective injunctive relief from violations of federal law” the Circuit Court found the Petitioner "did not seek prospective injunctive claims against the State Defendants in their official capacities" and thus Plaintiff's claims are barred on state sovereign immunity grounds.
As to Plaintiff's claims against the State Defendants in their individual capacities, the Circuit Court found that those claims "fail to state a cause of action".
Click HERE to access the Circuit Court of Appeals' decision posted on the Internet.