McKnight v. State of CT
MEMORANDUM DECISION denying 9 Motion for Injunction Relief ; denying 10 Motion for Writ of Mandamus; denying 24 Motion for Preliminary Injunction. Signed by Judge Mark R. Kravitz on 3/21/12. (Brown, S.)
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
ANTHONY MCKNIGHT, SR.,
STATE OF CONNECTICUT,
DEPARTMENT OF CORRECTIONS,
DEPARTMENT OF ADMINISTRATIVE :
COMPENSATION COMMISSION, and
OFFICE OF THE COMPTROLLER,
NO. 3:10cv1471 (MRK)
MEMORANDUM OF DECISION
Reading his pro se complaint generously, the Court finds that Plaintiff Anthony
McKnight, Sr. alleges inter alia that he suffered illegal discrimination and retaliation on the basis
of his race, religion, and disability in violation of Title VII of the Civil Rights Act of 1964, see
42 U.S.C. § 2000e-1 et seq., and the Americans with Disabilities Act (“ADA”), see 42 U.S.C.
§ 12101 et seq. Mr. McKnight brings suit against the State of Connecticut and four of its arms or
Now pending before the Court are Mr. McKnight's Motion for Injunctive Relief [doc.
# 9]; Petition for a Writ of Mandamus [doc. # 10]; and Motion for Injunctive Relief [doc. # 24].
For the reasons given below, all three motions are denied.
As an initial matter, because Mr. McKnight's complaint does not clarify for which claims
he seeks what forms of relief, the Court reviews its jurisdictional limitations. Under the Eleventh
Amendment, with limited exceptions, states and their agencies enjoy immunity from suits for
monetary damages—and, by extension, from this Court's jurisdiction. See, e.g., Seminole Tribe
of Fl. v. Florida., 517 U.S. 44, 68 (1996) ("[A]lthough a case may arise under the Constitution
and laws of the United States, the judicial power does not extend to it if the suit is sought to be
prosecuted against a State, without her consent, by one of her own citizens." (quotation marks
omitted)); Nat'l Foods, Inc. v. Rubin, 936 F.2d 656, 658-59 (2d Cir. 1991) ("[T]he Eleventh
Amendment has been interpreted to render states absolutely immune from suit in federal court
unless they have consented to be sued in that forum or unless Congress has overridden that
immunity by statute."). Eleventh Amendment immunity also extends to state agencies, "unless
the state has consented to suit or Congress has properly overridden the states' immunity." Bhatia
v. Conn., Dep't of Children & Families, No. 3:06 CV 1749 (MRK), 2007 WL 1033465, at *2 (D.
Conn. Apr. 3, 2007). However, sovereign immunity under the Eleventh Amendment does not bar
claims for declarative or injunctive relief. See, e.g., Fulton v. Goord, 591 F.3d 37, 45 (2d Cir.
Title VII was enacted pursuant to Congress's ability to abrogate state sovereign immunity
pursuant to § 5 of the Fourteenth Amendment, and so the Eleventh Amendment does not
necessarily bar all Title VII suits for monetary damages against states or their agencies. See
Fitzpatrick v. Blitzer, 427 U.S. 445 (1976) (finding that back pay and attorney fees in Title VII
actions are not precluded by the Eleventh Amendment). The Supreme Court has also provided a
test under which courts may analyze whether ADA claims may be maintained directly against a
state. See United States v. Georgia, 546 U.S. 151, 159 (2006) (describing test and noting that all
claims must be evaluated on a claim-by-claim basis). For the purposes of deciding these motions,
the Court assumes without deciding that the Georgia test is satisfied. Accordingly, Mr.
McKnight's non-Title VII and ADA claims for monetary damages are dismissed, but this Court
may exercise jurisdiction over Mr. McKnight's Title VII and ADA claims and any claims for
In his first Motion for Injunctive Relief [doc. # 9], as the Court understands it, Mr.
McKnight asks the Court to enjoin Defendants from requiring him to pay child support and to
remove the lien on his workers' compensation claim. Mr. McKnight states that the government's
actions are due to his race, but he provides no evidence to support this conclusory allegation. See
Mem. in Support [doc. # 9-1]. As Mr. McKnight has failed to state a claim upon which relief can
be based, his Motion for Injunctive Relief [doc. # 9] is denied. See Citigroup Global Mkts., Inc.
v. VCG Special Opportunities Master Fund Ltd., 598 F.3d 30, 34-35 (2d Cir. 2010) (noting that
motions for preliminary injunctive relief require a showing that the plaintiff is either likely to
succeed on the merits or that there are sufficiently serious questions going to the merits to make
them fair grounds for litigation).
Mr. McKnight's Motion for Writ of Mandamus [doc. # 10] requests the Court to order the
State of Connecticut and its agents to process his entitlement benefits to include hazardous duty
retirement pursuant to Connecticut General Statutes §§ 5-142(a); 5-169(i); 5-257(a).
This motion is barred by the Rooker-Feldman doctrine, which states that a federal court
lacks jurisdiction to review the decisions of a state court. See Rooker v. Fidelity Trust Co., 263
U.S. 413, 415-16 (1923); D.C. Ct. of Appeals v. Feldman, 460 U.S. 462, 483-84 n.16 (1983); see
also Exxon Mobil Corp. v. Saudi Basic Ind. Corp., 544 U.S. 280, 283 (2005) ("The RookerFeldman doctrine . . . is confined to cases of the kind from which the doctrine acquired its name:
cases brought by state-court losers complaining of injuries caused by state-court judgments
rendered before the district court proceedings commenced and inviting district court review and
rejection of those judgments.").
In 2001, the Superior Court of Connecticut, Judicial District of New Haven, dismissed a
similar request by Mr. McKnight on the basis that he failed to exhaust his administrative
remedies. See McKnight v. Armstrong, Comm'r of Corr., No. CV000446166, 2001 WL 862655,
at *1 (Conn. Super. Ct. Jul. 3, 2001) ("[Mr. McKnight's] claims for disability retirement under
§ 5-169(i) and hazardous duty retirement under § 5-173 contain no allegation that he sought
these benefits through the statutorily designated administrative agencies. In sum, McKnight has
not established through his petition or any other proof that he exhausted his previously available
administrative remedies. To the contrary . . . it appears that there were such remedies that were
available to him in 1994 that he chose not to pursue."). This Court cannot overturn a twelveyear-old state court decision in contravention of well-established principles of comity and
Mr. McKnight's second Motion for Injunctive Relief [doc. # 24] asks the Court to find
that the Revised 2011 Agreement between the State of Connecticut and State Employees
Bargaining Agent Coalition ("SEBAC") violates the Constitution and Connecticut state law. As
Mr. McKnight's state employment ended well over a decade ago and as he did not vest any
retirement interests, the Court finds that he does not have standing to challenge the Agreement.
Mr. McKnight has "not alleged an injury that would likely be redressed by a judgment in [his]
favor." OneSimpleLoan v. U.S. Sec'y of Educ., 496 F.3d 197, 201 (2d Cir. 2007) (citing Lujan v.
Defenders of Wildlife, 504 U.S. 555, 561 (1992)). Accordingly, the Court denies this motion.
Mr. McKnight's three pending motions [docs. # 9, 10, 24] are DENIED and all non-Title
VII or ADA claims for monetary damages are DISMISSED. As this order may result in the
dismissal of a number of Mr. McKnight's claims, including those based on allegations of fraud
and breach of contract, the Court orders Mr. McKnight to file a motion to amend his
complaint and a proposed amended complaint on or before April 20, 2012. The Court
recommends that Mr. McKnight clarifies what relief he seeks for his various claims. With regard
to any requests for monetary damages, the Court recommends that Mr. McKnight either pare
down his complaint to focus on his Title VII and ADA claims and/or move to add governmental
employees in their personal capacities.
The Court refers Mr. McKnight to its Notice of October 22, 2010, Or. [doc. # 3], for
additional guidance on the requirements for a complaint and reminds him that a complaint must
include "a short and plain statement of the claim," Fed. R. Civ. P. 8(b), supported by "sufficient
factual matter," Ashcroft v. Iqbal, --- U.S. ---, 129 S. Ct. 1937, 1949 (2009). If Mr. McKnight
does not file a motion to amend and proposed amended complaint on or before April 20,
2012, the Court will dismiss his case without prejudice.
IT IS SO ORDERED.
Mark R. Kravitz
United States District Judge
Dated at New Haven, Connecticut: March 21, 2012.
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