Reynolds v. Giuliani

Background

In a 2005 order, the court directed New York City and the New York City Human Resources Administration to provide Supplemental Nutrition Assistance Program benefits within seven days and immediate-needs cash grants on the day of application.

In December 2023, the plaintiffs sought to hold the City Defendants in civil contempt, meaning they asked the court to find that the defendants had violated the 2005 order. The parties later reached a settlement without admitting fault, liability, contempt, or violation of the 2005 order. On April 19, 2024, the court approved that settlement as a Corrective Action Plan, or CAP.

The CAP required monthly reporting about the timely processing of expedited Supplemental Nutrition Assistance Program benefits and the provision of food-related immediate-needs grants. It generally lasted nine months. It also provided for additional months if the defendants failed to meet specified performance standards, including a 95% timely-processing rate for expedited benefits or an average wait time of more than 90 minutes for a cash-assistance telephone system.

The parties agreed that the City Defendants met the 95% timely-processing standard every month. The City Defendants acknowledged that the 90-minute wait-time standard was exceeded in June, July, and September 2024, adding three months to the CAP. The CAP therefore ended no earlier than April 2025. The plaintiffs argued that the City Defendants still were not timely providing immediate-needs grants, but they expressly did not argue that the defendants were violating the CAP itself.

Plaintiffs’ Motion

The plaintiffs moved to extend the CAP for six more months and amend paragraphs three and five. They argued that doing so would help ensure compliance with the 2005 order and statutory deadlines. They cited data stating that timely assistance was provided to 73.8% of households experiencing a no-food emergency in January 2025 and 75.9% in February 2025.

Court’s Reasoning

The court explained that it retained authority to enforce the settlement because the settlement preserved the court’s jurisdiction. But that enforcement authority did not allow the court to rewrite the agreement by adding terms to which the parties had not agreed.

The court found that the CAP clearly limited its duration to nine months, subject to the specified extension conditions. The plaintiffs did not identify special circumstances, such as a breach of the CAP, that would permit the court to modify those terms. The court distinguished cases in which modification was allowed because the government had breached the settlement itself or because the parties had agreed to a revised settlement.

The court also rejected the argument that the CAP should be extended simply because doing so might further the purpose of the earlier contempt dispute. If the City Defendants were currently violating the 2005 order, the court stated that the plaintiffs’ remedy was to bring a new contempt motion based on that alleged violation, rather than modify the settlement resolving the earlier allegations.

Disposition

Judge Lewis J. Liman denied the plaintiffs’ motion to extend and modify the CAP. The clerk was directed to close the motion docket entry. The opinion did not decide whether the City Defendants violated the 2005 order or their statutory obligations concerning immediate-needs grants.