Ramirez v. City Of New York
- Subramanian
- 1:24-cv-01061
- U.S. District Court · Southern District of New York
- 2
In Ramirez v. City of New York, Judge Subramanian denied Ramirez’s sanctions motion, finding defendants made reasonable arguments about her pleadings.
Sally Ramirez’s request for Rule 11 sanctions was denied; the defendants were not sanctioned by this order.
What happened
In Ramirez v. City Of New York, Sally Ramirez asked the court to sanction the defendants under Rule 11 for allegedly making knowingly false arguments about Jewram’s role in selecting candidates for an Assistant Deputy Commissioner position.
Ramirez argued that later discovery showed the defendants’ statements were false and that the court had relied on them when granting an earlier motion to dismiss. The defendants’ motions had argued that Ramirez’s complaints did not adequately allege Jewram’s personal involvement in the hiring decision.
The court denied the sanctions motion. Judge Arun Subramanian explained that the defendants were making legal arguments about whether the complaints met pleading requirements, and that the court could consider only the facts alleged in the complaints at the motion-to-dismiss stage—not factual assertions from the defendants’ briefing.
The detailed version
- Ramirez v. City Of New York · No. 1:24-cv-01061
- Subramanian
- Apr. 9, 2025
Background
Sally Ramirez moved for sanctions under Rule 11, which allows a court to penalize improper filings or arguments. She argued that the defendants knowingly made false statements in two motions to dismiss by asserting that Jewram had no involvement in posting, interviewing, hiring, or selecting candidates for the Assistant Deputy Commissioner position. Ramirez maintained that later discovery showed Jewram was directly involved in the hiring process.
The Parties’ Arguments
The defendants’ motions to dismiss argued that Ramirez had not adequately alleged Jewram’s personal involvement in selecting or hiring the candidate. The court characterized those statements as legal arguments about whether Ramirez’s complaints met the requirements for pleading a plausible claim, rather than as arguments about what later discovery showed.
Ramirez also argued that the statements were especially harmful because the court relied on them in granting the defendants’ first motion to dismiss. The court explained that, at the motion-to-dismiss stage, it must generally treat the complaint’s factual allegations as true and cannot consider factual assertions outside the complaint. Therefore, it said it could not—and did not—rely on factual assertions in the defendants’ motion papers when deciding the motions.
Ruling
The court held that the defendants’ conduct did not come close to warranting sanctions. It found that the defendants had made reasonable legal arguments identifying alleged deficiencies in how Ramirez pleaded her case, regardless of whether Jewram was actually involved in the hiring process.
The court denied Ramirez’s motion for sanctions and directed the Clerk of Court to terminate the motion at Dkt. 61. Judge Arun Subramanian signed the order on April 9, 2025.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.