Bishop v. Trustees of St. Joseph's College
- Garnett
- 1:25-cv-05788
- U.S. District Court · Southern District of New York
- 2
In Bishop v. Trustees of St. Joseph’s College, Judge Garnett ordered settlement talks and paused the defendant’s response deadline without deciding the case.
Cedric Bishop and the Trustees of St. Joseph’s College, including their counsel, must follow the settlement-discussion, joint-letter, and response-deadline requirements.
What happened
In Bishop v. Trustees of St. Joseph’s College, the court ordered the parties to meet for at least one hour within 30 days after the defendant is served, and to make a good-faith effort to settle. They must discuss whether the plaintiff has standing and whether the website involved is a standalone website that qualifies as a public accommodation under the Americans with Disabilities Act.
Within 15 more days, the parties must file a joint letter stating whether they settled. If they did not, the letter must request mediation, a settlement conference with a magistrate judge, or an initial status conference, and must state whether the defendant plans to answer or ask the court to dismiss the complaint.
Judge Margaret M. Garnett stayed the defendant’s deadline to answer or otherwise respond until the joint letter is filed. The court will then set either a new answer deadline or a schedule for a dismissal motion; the order did not decide the claims’ merits.
The detailed version
- Bishop v. Trustees of St. Joseph's College · No. 1:25-cv-05788
- Garnett
- July 16, 2025
Order and Settlement Discussions
The court ordered the parties to meet and confer for at least one hour within 30 days after service of the summons and complaint on the defendant. The parties must make a good-faith attempt to settle the action.
As part of those discussions, the parties must consider whether the plaintiff has satisfied the threshold requirement of standing, meaning a sufficient personal connection to bring the case. They must also consider whether the website at issue is a “standalone website,” which the order describes as a business website without a physical location, and whether such a website is a “place of public accommodation” under Title III of the Americans with Disabilities Act, a federal law addressing disability discrimination in public accommodations. The order cites decisions from the Southern District of New York addressing those issues but does not decide them in this case.
Joint Letter and Next Steps
Within 15 additional days—45 days after service—the parties must submit a joint letter stating whether they settled. If they did not settle, the letter must ask the court either to refer the case to mediation or to a magistrate judge for a settlement conference, while indicating a preference, or to proceed with an initial status conference.
The joint letter must also state whether the defendant intends to answer the complaint or file a motion to dismiss. If the defendant anticipates filing a motion to dismiss, the letter must briefly state the basis for that motion in no more than one paragraph.
Disposition
The court stayed the deadline for the defendant to answer or otherwise respond to the complaint until the parties submit the joint letter. After that filing, the court will set a deadline for the answer or a briefing schedule for a motion to dismiss. Judge Margaret M. Garnett’s order is a case-management and settlement order; it does not resolve standing, the website’s status, or the merits of the action.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.