Rusfeldt v. City of New York, New York
- P. Castel
- 1:22-cv-00594
- U.S. District Court · Southern District of New York
- 4
In Rusfeldt v. City of New York, Judge Castel denied Rusfeldt’s motion to delay trial and ordered the first phase to begin June 16, 2025.
Pastor Aden Rusfeldt, the City of New York, and Stephen Hughes; the order controls the timing and phased structure of discovery and trial.
What happened
In Rusfeldt v. City of New York, Pastor Aden Rusfeldt asked the court to delay the first phase of trial until discovery was completed on his claim against the City of New York. That claim alleges the City was responsible for a policy, practice, custom, or usage connected to an allegedly unlawful arrest.
The court had separated discovery and trial into phases. The first phase concerns whether defendants violated Rusfeldt’s constitutional rights and, if so, his damages. The court planned to address the City-related claim only if Rusfeldt first proved an underlying constitutional violation. Rusfeldt again asked to lift the pause on discovery for that claim and delay trial.
Judge P. Kevin Castel denied the letter motion. He ordered the first-phase trial to begin June 16, 2025, at 10:00 a.m., and stated that damages against Stephen Hughes would be decided in that first phase if the jury found Hughes liable.
The detailed version
- Rusfeldt v. City of New York, New York · No. 1:22-cv-00594
- P. Castel
- Mar. 27, 2025
Background
Pastor Aden Rusfeldt was arrested by New York City Police Department officers on June 27, 2021. In an earlier summary-judgment ruling, the court found a factual dispute about whether there was probable cause for the arrest. The court stated that, if Rusfeldt proves at trial that the arrest lacked probable cause, it expects to allow discovery on whether the arrest resulted from a pattern, practice, custom, or usage of the City of New York. This is the municipal-liability claim commonly called a Monell claim.
The court divided discovery into phases. The first phase covers whether any defendant violated Rusfeldt’s rights under the First, Fourth, or Fourteenth Amendments in connection with events at or near the June 27, 2021 Pride Festival, and any resulting damages. The phase excludes allegations that defendants acted under municipal policies, practices, procedures, or customs. The court later granted in part and denied in part the defendants’ summary-judgment motion and denied Rusfeldt’s summary-judgment motion. It then scheduled a first-phase trial while keeping discovery on the municipal-liability claim paused.
Motion and ruling
Rusfeldt filed another letter motion asking the court to delay the trial until discovery on the municipal-liability claim was complete. The court denied the motion. It relied on the principle that a municipality cannot be liable under this theory unless an underlying constitutional or federal-law violation occurred, and on its authority under Rules 16(c)(2)(M) and 42(b) of the Federal Rules of Civil Procedure to divide discovery and trial into phases. The court concluded that proceeding first with the underlying constitutional claims could eliminate the need for a municipal-liability trial, conserve judicial resources, and avoid unfair prejudice to Hughes.
The court set the first-phase trial for June 16, 2025, at 10:00 a.m. It also clarified that if the jury finds Hughes liable, it will decide damages against him during the first phase. The order states: “Letter motion (ECF 139) is DENIED.”
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.