New York State cannot be forced to investigate a psychologist accused by a human rights organization of overseeing coercive interrogation tactics at Guantánamo Bay, Cuba, a judge in Manhattan ruled on Thursday.

The rights group, the Center for Justice and Accountability, had brought a suit claiming that the psychologist, John Francis Leso, helped develop a plan of coercive techniques, including sleep deprivation and isolation, to use on detainees at Guantánamo. The suit was brought on behalf of Steven Reisner, a psychologist and an assistant professor of clinical psychiatry at the New York University School of Medicine. It sought an investigation of Dr. Leso by a professional disciplinary office in the state’s Education Department that regulates psychologists’ licenses.

But in a 12-page ruling filed in State Supreme Court, Justice Saliann Scarpulla wrote that Dr. Reisner had no standing to force an investigation. Nothing in state education law, Justice Scarpulla wrote, guarantees that the office “formally investigate every single complaint of professional misconduct, no matter the contents or applicability of the complaint.”

The judge also ruled that Dr. Reisner did not suffer an injury as a result of the state’s decision not to investigate.