Doe v. Combs

Background

John Doe, proceeding anonymously, brought a claim under New York City’s Victims of Gender-Motivated Violence Protection Law. The defendants moved to dismiss the complaint. The parties then jointly moved to stay, or pause, the case while the Second Circuit considered two appeals: Parker v. Alexander, No. 25-487, and Doe v. Black, No. 25-564.

Issue affecting the stay

The appeals were expected to address whether the city law is preempted—overridden by conflicting state law—by New York’s Child Victims Act or Adult Survivors Act. Those state laws created periods for bringing certain claims that otherwise would have been barred by the statute of limitations. In an earlier case, one district court held that the city law was not preempted, while another held that it was preempted. The defendants relied on the same preemption argument in seeking dismissal here.

Court’s reasoning

The court explained that it may pause a case to manage its docket efficiently. It considered that both sides requested the stay, the Second Circuit’s decisions could provide guidance, and continuing without that guidance could lead to an inconsistent ruling and additional delay. The court also found that a stay could avoid unnecessary litigation costs and preserve judicial resources.

Disposition

Judge Rochon granted the parties’ joint request to stay the case pending resolution of the appeals in Parker and Black. The parties must file a joint status letter by August 14, 2025, and every 90 days afterward. The clerk was directed to terminate the stay motion at Docket 72 and mark the case as stayed. The opinion did not decide the defendants’ motion to dismiss or the preemption question.