Johnson v. Starwood Hotels & Resorts Worldwide, LLC
- Subramanian
- 1:23-cv-01156
- U.S. District Court · Southern District of New York
- 2
In Johnson v. Starwood Hotels, Judge Subramanian denied Joseph Johnson’s request to change the judgment and his request for a new trial.
Joseph Johnson’s post-judgment request was denied, leaving the final judgment closing the case in place.
What happened
In Johnson v. Starwood Hotels & Resorts Worldwide, LLC, Joseph Johnson asked the court to change the final judgment under a federal rule that allows judgments to be changed for a clear legal error or to prevent serious unfairness.
The court said Johnson’s motion and declaration did not clearly explain what relief he wanted. The court understood his request to refer to attachments to his complaint, which it had already reviewed when it dismissed the complaint. Johnson also requested a new trial, but no trial had occurred.
Judge Arun Subramanian denied the motion because Johnson did not identify a clear legal error or explain why changing the judgment was necessary to prevent serious unfairness. The court also denied the request for a new trial and directed the Clerk of Court to terminate the motion.
The detailed version
- Johnson v. Starwood Hotels & Resorts Worldwide, LLC · No. 1:23-cv-01156
- Subramanian
- Apr. 24, 2025
Background
On March 7, 2025, the court granted Starwood Hotels & Resorts Worldwide, LLC’s motion to dismiss Joseph Johnson’s complaint. The Clerk of Court then entered a final judgment closing the case.
Johnson filed a motion under Federal Rule of Civil Procedure 59(e), which permits a court to alter or amend a judgment in limited circumstances. He also requested a new trial in the same motion. The court explained that a Rule 59(e) motion must seek a substantive change to the judgment and may be granted to correct a clear error of law or prevent manifest injustice.
Court’s analysis
The court found that Johnson’s motion did not make clear what relief he sought. Neither the motion nor his accompanying declaration explained the request. The declaration asked the court to “read the attachments” that were separate from the motion. The court assumed Johnson meant the attachments to his complaint, which the court had already reviewed when deciding the motion to dismiss.
Because Johnson did not identify a clear error of law or explain why amending the judgment was necessary to prevent manifest injustice, the court denied the Rule 59(e) motion. The court also denied Johnson’s request for a new trial because there had been no trial.
Disposition
Judge Arun Subramanian denied the motion and directed the Clerk of Court to terminate the motion at Docket 146.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.