Robinson v. United States Small Business Administration

ln( UNITED STATES DISTRICT CQURT MAR _ 8 2014 FoR THE DISTRICT 0F C0LUMB1A clerk u_s Dismct and Bankruptcy Courts ) DAvID RoBrNsoN, JR., ) ) Plainriff, ) ) _ v. ) Civil Action No. l 4 v A` ) UNITED sTATEs sMALL BUsINEss ) ADMINISTRATIoN, er az., ) ) Defendants. ) ) MEM0RAN1)UM oP1N1oN This matter is before the Court on Plaintiff’ s application to proceed in forma pauperis and his pro se complaint. The Court will grant the application and dismiss the complaint. According to plaintiff, Borrego Springs Bank denied his loan application upon its conclusion that plaintiff was ineligible to participate in a loan program under the auspices of the Small Business Administration. Compl. 11 2(). In plaintiffs view, this action not only violated rights protected under the First, Fifth and Fourteenth Amendments to the United States Constitution, see id. 1111 23-25, but also amounted to a conspiracy to deprive him of constitutional rights, see ia'. 11 26.1 l Plaintiff’ s reliance on 18 U.S.C. §§ 241 and 242, see Compl. 11 26, is misplaced, as there is no private right of action under these criminal statutes. See, e.g., P0pe v. Thornburgh, 978 F.2d 744 (D.C. Cir. l992) (per curiam); McCray v. Holder, No. l0-0()26, 2010 WL 55300, at *l (D.D.C. Jan. 6, 2010), cyj"d, 391 F. App’x 887 (D.C. Cir. 20l0) (per curiam). Under the doctrine of resjudicata, a prior judgment on the merits of a claim bars a plaintiff from relitigating the same claim. See I.A.M. Nat'l Pension Funa’ v. Indus. Gear Mfg. C0., 723 F.2d 944, 949 (D.C. Cir. l983) (noting that res judicata “forecloses all that which might have been litigated previously"). "[W]here res judicata applies, it bars relitigation not only as to all matters which were determined in the previous litigation, but also as to all matters that might have been determined." Natuml Res. Def Council, Inc. v. Thomas, 838 F.2d l224, 1252 (D.C. Cir. l988) (citation omitted); see Allen v. McCurry, 449 U.S. 90, 94 (l980). ln evaluating a cause of action for res judicata purposes, it is the factual nucleus that gives rise to a plaintiffs claim, not the legal theory on which the claim rests, that determines whether the claim may proceed. Page v. Unz'ted Staz‘es, 729 F.2d 8l8, 820 (D.C. Cir. l984). As plaintiff notes, Compl. 11 31, a prior civil action challenged the same denial of his loan application, and that action was dismissed because the complaint failed to state a claim under 42 U.S.C. § 1983 upon which relief could be granted. See Robinson v. U.S. Small Business Aa’min., No. 13-0863, 2013 WL 4574935 (D.D.C. June 10, 2013). Plaintiff cannot avoid application of the doctrine by presenting new legal theories for recovery. The Court concludes that plaintiffs claims are barred under the doctrine of resjudicata, and, accordingly, the complaint will be dismissed. An Order accompanies this Memorandum &>\ . 77 m q U{ United States District Judge Opinion.