McKinney v. Combs
- Naomi Buchwald
- 1:24-cv-03931
- U.S. District Court · Southern District of New York
- 2
In McKinney v. Combs, Judge Buchwald stayed the case until the Second Circuit resolves related statute-of-limitations appeals.
Crystal McKinney, Sean Combs, Bad Boy Entertainment LLC, Bad Boy Entertainment Holdings, Inc., and Sean John Clothing LLC; the pending motion to dismiss will remain stayed until the Second Circuit resolves the related appeals.
What happened
McKinney sued Sean Combs and three related companies under New York City’s Victims of Gender-Motivated Violence Protection Act. The opinion says the complaint asserted one claim.
The defendants’ motion to dismiss is pending, and it primarily raises statute-of-limitations issues. The court identified at least two pending Second Circuit appeals involving similar issues, and neither side objected to pausing this case.
Judge Naomi Reice Buchwald ordered a formal stay until the Second Circuit resolves those appeals. The order does not decide whether McKinney’s claim is timely or whether the motion to dismiss should be granted.
The detailed version
- McKinney v. Combs · No. 1:24-cv-03931
- Naomi Buchwald
- Apr. 24, 2025
Background
Crystal McKinney filed a complaint against Sean Combs, also known as “P. Diddy,” Bad Boy Entertainment LLC doing business as Bad Boy Records, Bad Boy Entertainment Holdings, Inc., and Sean John Clothing LLC. The complaint asserted one cause of action under the New York City Victims of Gender-Motivated Violence Protection Act.
Prior and Pending Motions
The order states that the defendants’ request to file a motion to dismiss, primarily on statute-of-limitations grounds, was granted on October 1, 2024. It also states that the defendants’ motion to dismiss was pending before the court. The opinion does not explain the apparent relationship between the earlier granted request and the pending motion beyond those statements.
Reason for the Stay
The court identified at least two pending appeals before the Second Circuit involving similar statute-of-limitations issues. The court stated that the Second Circuit’s decision on that potentially case-ending legal issue would be binding. On April 8, 2025, the court proposed staying this case until the appeals were resolved, and neither party objected.
Ruling
Judge Naomi Reice Buchwald ordered that a formal stay be imposed until the Second Circuit resolves the pending appeals. The order does not decide the statute-of-limitations issue, the merits of McKinney’s claim, or the pending motion to dismiss.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.