In Simon v. City of New York, plaintiff Alexina Simon sued the City, police officers, and an assistant district attorney under 42 U.S.C. § 1983, claiming her civil rights were violated when she was detained in August 2008 as a material witness in a vehicle theft investigation after failing to respond to a subpoena. The court had previously adopted a magistrate judge's report concluding that the claims were barred by absolute or qualified immunity. Defendants moved for summary judgment, and the district court granted the motion, dismissing the case with prejudice. The core reasoning was that the assistant district attorney's actions in obtaining the material witness order and warrant were objectively reasonable and protected by immunity, while the Monell claim against the City failed for lack of evidence of an unconstitutional municipal policy or custom.
This case involved a challenge by preservation groups to decisions by the National Park Service approving the use of two historic structures in Brooklyn Bridge Park for commercial and cultural purposes, based on maps submitted under the Land and Water Conservation Fund Act. Plaintiffs alleged violations of the LWCFA, NEPA, NHPA, the APA, and New York's public trust doctrine. The court granted summary judgment to plaintiffs on the LWCFA and APA claims, holding that NPS decisions were not supported by the administrative record and vacating those decisions while remanding to the agency. The other federal claims were dismissed as moot, and the court declined to exercise supplemental jurisdiction over the state-law claim due to its complexity and a parallel state proceeding. The preliminary injunction was dissolved as a result.
Plaintiff Jesse Kmec sued his employer, PATH, under the Federal Employers' Liability Act for injuries to his left arm sustained while unloading a steel pipe at work on May 5, 2009. After a bifurcated trial, the jury found both parties 50% at fault and awarded damages including $50,000 total for past and future pain and suffering. Kmec moved for a new trial under Federal Rule of Civil Procedure 59, arguing that the pain and suffering awards were shockingly inadequate given his displaced ulna fracture, two surgeries involving hardware insertion and bone grafting, ongoing pain, physical therapy, and the likelihood of a third surgery. The court granted the motion after reviewing the evidence of pain from the injury and procedures, expert testimony on future pain and impairment, and comparable verdicts, concluding that the awards failed to meet the conscience-shocking standard.
In Martin v. City of New York, plaintiff Isa Martin sued the City of New York and several police officers under 42 U.S.C. § 1983, alleging civil rights violations including false arrest, malicious prosecution, and related state-law claims after his June 2007 arrest for possession of a loaded firearm. Martin was arraigned, unable to post bail immediately, and held at Rikers Island, where he was assaulted by another inmate who held a prior grudge against him; the charges were later dismissed. The defendants moved for partial summary judgment, which the court granted, while denying Martin's cross-motion. The court held that even assuming a viable malicious prosecution claim, there was no proximate causation linking the arrest or remand to Martin's injuries, as the assault was an independent, unforeseeable act by the other inmate that broke any chain of causation. The decision rested on the absence of evidence that the officers could have reasonably foreseen the specific risk of assault at the facility.
In Leroy v. New York City Board of Elections, pro se plaintiff Mireille P. Leroy sued the Board of Elections after it rejected her petition to appear on the Democratic primary ballot for City Council due to defects in the cover sheet and volumes, alleging due process violations, gender discrimination, and a conflict of interest under federal law, and seeking damages. After state courts dismissed her challenges as untimely and the federal court denied injunctive relief, the district court granted the Board's motion to dismiss the remaining damages claims under Rule 12(b)(6). The court reasoned that candidates have no protected property interest in ballot access or elected office, that state court proceedings provided adequate process, and that the discrimination and conflict claims were conclusory or unsupported by law.
The case involved pro se petitioner Rafael Parnell’s habeas corpus petition under 28 U.S.C. § 2254 challenging his state conviction for criminal possession of a controlled substance. During jury selection, both parties raised Batson challenges alleging racially discriminatory peremptory strikes, which the trial court addressed by requiring explanations and sustaining some objections before seating the jury. Later, during deliberations, a juror expressed safety concerns after possibly recognizing Parnell, but affirmed he could remain fair and impartial; the court denied defense requests to discharge the juror or question him outside Parnell’s presence. Parnell also claimed his sentence was excessive, but the court held it fell within the statutory range for a second felony offender and thus raised no federal constitutional issue. The district court denied the petition in full, finding no basis for habeas relief on these claims.
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