# Opinion

> District Court, D. New Jersey · January 13, 2026

URL: https://www.frixlaw.com/law-library/cases/11243141

## Case

- **Full name:** Deonca Williams v. American Arbitration Association Inc., et al.
- **Court:** District Court, D. New Jersey
- **Decided:** January 13, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11243141. Public record. Not legal advice.