Stinson v. City University of New York
- Lewis Liman
- 1:17-cv-03949
- U.S. District Court · Southern District of New York
- 5
In Stinson v. City University of New York, Judge Liman denied Stinson’s motions to vacate the judgment and amend his complaint.
Marcus Stinson’s attempt to reopen the June 2018 judgment and file another amended complaint was denied. The 2018 dismissal of his employment-discrimination claims was not vacated.
What happened
Marcus Stinson asked the court to set aside a June 2018 judgment that had dismissed his employment-discrimination claims against City University of New York and the other defendants, or to let him file another amended complaint. The case is Stinson v. City University of New York.
Stinson argued that the earlier decision misstated the facts, that later-discovered records showed undisclosed involvement by the City University Construction Fund, and that the original judge should have been removed because of political connections. He filed the motion without a lawyer, more than six years after the judgment, and did not appeal that judgment.
The court ruled that the requests based on mistake, new evidence, or misconduct were too late; the judgment was not legally void; and the alleged political connections did not show significant doubt about the judge’s fairness. Judge Liman also denied leave to file another amended complaint because Stinson had already received several opportunities to amend and had not shown a valid reason to reopen the judgment.
The detailed version
- Stinson v. City University of New York · No. 1:17-cv-03949
- Lewis Liman
- Sept. 4, 2024
Background
Marcus Stinson moved under Federal Rule of Civil Procedure 60 to set aside or vacate the June 6, 2018 judgment, or alternatively for leave to file an amended complaint. The 2018 judgment followed an order dismissing his Second Amended Complaint, which alleged employment discrimination based on race and disability under federal and state statutes. Stinson filed the current motion without a lawyer. The court stated that he had previously been represented by counsel, had amended his complaint twice, and had not appealed the 2018 judgment.
Arguments
Stinson argued that the earlier opinion altered, omitted, or misrepresented facts. He also relied on records concerning the City University Construction Fund and a settlement involving a CUNY employee, arguing that those records showed the Fund’s involvement in his employment relationship and that CUNY and the Research Foundation of the City University of New York had not disclosed that involvement. He argued that the judgment was therefore void and that fraud had occurred. He also argued that the judge who dismissed his claims should have been removed because of ties to New York politicians connected to one of the defendants. Finally, he requested permission to file another amended complaint.
Court’s analysis
Rule 60(b) permits relief from a final judgment for specified reasons, including mistake, newly discovered evidence, misconduct, a void judgment, or another extraordinary reason. Requests based on mistake, newly discovered evidence, or misconduct must be made within one year after the judgment. The court held that Stinson’s claims under those provisions were too late because the judgment was entered in June 2018 and the motion was filed more than six years later. The court also stated that discovering evidence later does not change Rule 60(c)’s one-year deadline.
The court rejected the argument that the judgment was void. A judgment is void on this ground only when the court lacked the power to decide the case. Because Stinson’s claims arose under federal law or were related to federal-law claims, the court held that it had jurisdiction. The court also declined to grant relief under Rule 60(b)(6), which is available only for reasons that do not fit within the other Rule 60(b) grounds. The court therefore would not reconsider the alleged errors in the original judgment or the newly discovered evidence under that provision.
The court further held that the allegations about political connections did not establish significant doubt about the original judge’s ability to decide the case fairly. It denied leave to amend because post-judgment amendment requires a valid reason to vacate the judgment, and Stinson had already had several opportunities to amend his complaint.
Disposition
The motion to vacate was DENIED, and the motion for leave to file an amended complaint was DENIED. The Clerk of Court was directed to close the docket entry for the motion. This order addressed whether the 2018 judgment could be reopened; it did not decide the underlying employment-discrimination claims again.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.