Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

DEONCA WILLIAMS,

Civil Action No. 25-12412 (JXN)(CF)

Plaintiff,

v.

AMERICAN ARBITRATION

MEMORANDUM ORDER

ASSOCIATION INC., et al.,

Defendants.

NEALS, District Judge

WHEREAS, Plaintiff Sharita T. Patterson (“Plaintiff”), appearing pro se, has filed a

Complaint against Citibank N.A. (“Citibank”) and the American Arbitration Association (“AAA”)

(collectively, “Defendants) (see Complaint (“Compl.”), ECF No. 1); and

WHEREAS, Plaintiff’s claims arise from a collection action Citibank filed in the Superior

Court of New Jersey, Law Division, Special Civil Part, Hudson County, regarding the Sears

Mastercard credit account Plaintiff had with Citibank and the subsequent arbitration of this matter

by the parties with the AAA. (See generally Compl.) Plaintiff alleges that Defendants are “working

together to ignore all evidence and demand arbitration to deny Plaintiff’s rights to have issues

heard in a Federal Court” (Compl. at *3)1; and

WHEREAS, in submitting an IFP application, the Complaint is subject to sua sponte

screening and may be dismissed if, among other things, the action is frivolous or malicious or fails

1 Page numbers preceded by an asterisk (*) reflect CM/ECF pagination.

to comply with the proper pleading standards.”2 See 28 U.S.C. § 1915(e)(2)(B)(i)–(iii); Brown,

941 F.3d at 662.

WHEREAS, it appears to the Court that Plaintiff’s Complaint is duplicative of a currently

pending case Plaintiff brought against Citibank, involving the same subject matter, challenging the

same arbitration, and raising nearly identical claims and factual allegations, see Williams v.

Citibank N.A. et al, Civil Action No: 25-01044 (MCA)(JBC); and

WHEREAS, “[a]s part of its general power to administer its docket, a district court may

dismiss a duplicative complaint,” Fabics v. City of New Brunswick, 629 F. App’x 196, 198 (3d

Cir. 2015) (quoting Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 817

(1976)) (internal quotations omitted); (citing Walton v. Eaton Corp., 563 F.2d 66, 70 (3d Cir.

1977)) (en banc) (prohibiting a plaintiff from “maintain[ing] two separate actions involving the

same subject matter at the same time in the same court and against the same defendant”); Gause

v. Court of Common Pleas, 571 F. App’x 144, 145 (3d Cir. 2014) (a district court may properly

dismiss duplicative complaints under § 1915(e)) (citing Pittman v. Moore, 980 F.2d 994, 994–95

(5th Cir. 1993)); and

WHEREAS, to the extent Plaintiff wishes to sue the other defendants they have named in

this matter, like the AAA, Plaintiff may move to amend their complaint in the previously filed

action to add those defendants and factual allegations against them. See Elgin v. Dep't of Treasury,

567 U.S. 1, 34 (2012) (“Plaintiffs generally must bring all claims arising out of a common set of

facts in a single lawsuit, and federal district courts have discretion to enforce that requirement as

2 “[A] court has the discretion to consider the merits of a case and evaluate an IFP application in either order or even

simultaneously.” Brown v. Sage, 941 F.3d 655, 660 (3d Cir. 2019).

necessary ‘to avoid duplicative litigation.’”) (Alito, J., dissenting) (quoting Colorado River, 424

U.S. at 817). Accordingly,

IT IS on this 13th day of January 2026,

ORDERED that this action is ADMINISTRATIVELY TERMINATED as duplicative

of Civil Action No. 25-01044; it is further

ORDERED that the Clerk of the Court shall docket this Order for informational purposes

only in Civil Action No. 25-01044; and it is further

ORDERED that the Clerk of the Court shall CLOSE this matter.

_______________________

JULIEN XAVIER NEALS

United States District Judge