This column addresses recent noteworthy decisions of the U.S. District Court for the Northern District of New York. This installation focuses on two decisions granting motions to dismiss: the first, a high-profile decision by Judge Brenda K. Sannes dismissing claims brought by former president Donald Trump against New York Attorney General Letitia James after finding that both Younger abstention and res judicata justified dismissal; and the second, a decision by Judge Gary L. Sharpe dismissing an action alleging violations of the Defend Trade Secrets Act and accompanying state law claims for lack of personal jurisdiction and lack of capacity to sue.

Judge Sannes Dismisses Trump's Claims Against Letitia James

On May 27, 2022, Judge Sannes dismissed a complaint brought by Donald Trump and his business organizations against Attorney General Letitia James, asserting that James's investigation of Trump and his business organizations violated his rights under the First, Fourth and Fourteenth Amendments and abused the judicial process to advance James's own political ambitions. Trump et al. v. James, 1:21-cv-1352 (BKS/CFH), 2022 WL 1718951 (N.D.N.Y. May 27, 2022). In addition to a declaratory judgment, plaintiffs sought preliminary and permanent injunctions to either cease or limit the investigation. Id. at *4.

In a lengthy discussion, Judge Sannes found this case to be a straightforward application of Younger abstention, in which the Sprint and Middlesex factors all weighed in favor of abstention. See id. at *8-*12. The court evaluated—and eventually rejected—plaintiffs' argument that the bad-faith exception to Younger applied, holding that the fact that James's "public statements reflect personal and/or political animus toward Plaintiffs is not, in and of itself, sufficient." Id. at *13. The court further found that plaintiffs failed to establish that the New York proceeding, in which James sought compliance with several subpoenas issued to plaintiffs, was commenced for the purpose of harassing plaintiffs. Id.