Pryce v. Gonyo

Background

Camay Pryce sued Trooper Investigator Christopher Gonyo, Trooper James Huestis, Trooper Investigator Peter Maczkiewicz, and Trooper Harry Kerr, individually and as employees of the State of New York. New York State’s Office of the Attorney General was identified as an interested party.

Pryce’s complaint asserted two federal claims: a claim under 42 U.S.C. § 1983 alleging that the defendants fabricated evidence, denying her a fair trial and due process, and a claim alleging violation of her Fourteenth Amendment right to equal protection. The claims were based on evidence allegedly introduced at her first state criminal trial and used to obtain her conviction.

On October 31, 2024, the state conviction was vacated. The state court ordered a new trial on the state charge, tentatively scheduled for January 13, 2025. The defendants asked the federal court to pause the case until the state criminal proceeding ended, or alternatively to set a schedule for a planned motion to dismiss. Pryce opposed a stay.

Reasons for the Stay

The court applied the rule from Younger v. Harris, which generally limits federal courts from interfering with ongoing state proceedings. The court found the required conditions: Pryce’s state criminal case was ongoing, the state had an important interest in prosecuting it, and temporarily pausing the federal case would not eliminate Pryce’s opportunity to have her federal constitutional claims reviewed.

The court concluded that the result of the second state trial could affect the federal claims. In particular, the second trial might or might not cure the alleged defects in the first trial. That result could determine the scope or outcome of Pryce’s claim that fabricated evidence led to her loss of liberty.

The court also separately considered its inherent authority to pause proceedings. It found that a stay could clarify the claims, avoid unnecessary or duplicative briefing, conserve judicial resources, and likely be short because the state trial was tentatively scheduled for January 2025. The court found that Pryce had not given a persuasive reason why a stay would prejudice her.

Disposition

The court ordered that the action be stayed until resolution of Pryce’s state criminal case. The parties were directed to inform the court of the final adjudication of that case no later than fourteen days after its resolution. The opinion decided the stay request and did not decide the merits of Pryce’s federal claims. Judge Kenneth M. Karas signed the order.