MCNAUGHTON v. BLASIO 14 LLP LLC DOE 200 200 DOE DOE 200 (2021)

United States Court of Appeals, Second Circuit.2021-08-27No. 20-3778

Summary · law.co

Holding. The appellate court affirmed the district court's dismissal of the complaint and its refusal to allow amendment, agreeing with the lower court's reasoning that the claims failed to meet pleading standards and lacked merit.

Neil McNaughton, a retired attorney representing himself, filed a federal lawsuit against New York City officials, private citizens, and numerous unnamed defendants alleging a widespread conspiracy involving the police department, his residential cooperative, and private parties. He claimed they engaged in a coordinated campaign to harass and defame him through false accusations of child sexual abuse, asserting violations of federal constitutional rights as well as state law causes of action for defamation, breach of contract, and fraud.

The district court dismissed the complaint on its own initiative, finding that McNaughton failed to allege sufficient facts to support his claims, that the allegations lacked plausibility, and that the complaint was frivolous. The court also declined to take jurisdiction over the state law claims and refused to permit McNaughton to file an amended complaint, concluding that any amendment would be futile. McNaughton appealed the dismissal and the denial of amendment rights.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Sufficiency of allegations to state a federal civil rights claim under 42 U.S.C. § 1983
Plausibility of conspiracy allegations against government and private defendants
Propriety of dismissal for frivolousness
Futility of permitting amendment to cure defects in the complaint

Procedural posture

McNaughton appealed a district court order dismissing his pro se complaint and denying leave to amend.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

SUMMARY ORDER

Neil McNaughton, a retired attorney proceeding pro se, sued several New York City officials, multiple civilians, and hundreds of Jane and John Does under 42 U.S.C. § 1983 alleging various constitutional violations and state law claims, including defamation, contract, and fraud. His complaint alleged a years-long conspiracy among the New York City Police Department, his apartment cooperative, and private citizens aimed at harassing and defaming him based on false accusations of pedophilia.

The district court sua sponte dismissed McNaughtons complaint, reasoning that he failed to state a claim, his allegations were implausible, and his complaint was frivolous. The court also declined to exercise supplemental jurisdiction over McNaughtons state law claims and declined to grant leave to amend his complaint as futile. McNaughton appeals. We affirm the district courts dismissal and denial of leave to amend for substantially the same reasons articulated by the district court. See generally McNaughton v. de Blasio, No. 20-CV-6991 (JMF), 2020 WL 5983100 (S.D.N.Y. Oct. 8, 2020).

We have considered all of McNaughtons remaining arguments and find them to be without merit. Accordingly, the order of the district court hereby is AFFIRMED.