Urena v. The City of New York
- Jesse Furman
- 1:24-cv-01886
- U.S. District Court · Southern District of New York
- 5
In Urena v. City of New York, Judge Furman granted dismissal because Urena’s earlier release covered these civil-rights claims.
Amaury Urena’s federal civil-rights claims against the City of New York and two City employees were barred by the releases and the defendants received judgment; the court also declined to allow amendment and denied Urena permission to appeal without paying filing fees.
What happened
In Urena v. The City of New York, Amaury Urena, a state prisoner without a lawyer, claimed under federal civil-rights law that the defendants subjected him to unconstitutional conditions of confinement. The claims concerned events from March 17, 2021, through February 29, 2024.
While this case was pending, Urena settled a different civil case and signed broad releases covering civil-rights claims against City officials and employees through November 1, 2024. The defendants argued that those releases covered the claims here. Urena argued that the releases were unclear, that he did not knowingly release his pending claims, and that the settlement consideration was inadequate.
Judge Jesse M. Furman ruled that the releases clearly covered Urena’s claims and granted the defendants’ motion to dismiss. The court declined to allow Urena to amend, entered judgment for the defendants, closed the case, and denied him permission to appeal without paying filing fees.
The detailed version
- Urena v. The City of New York · No. 1:24-cv-01886
- Jesse Furman
- Aug. 18, 2025
Background
Amaury Urena, a state prisoner proceeding without a lawyer, sued the City of New York and two City employees under 42 U.S.C. § 1983. He alleged that events occurring between March 17, 2021, and February 29, 2024, amounted to unconstitutional conditions of confinement.
While this case was pending, Urena settled a prior related proceeding in the Southern District of New York. As part of that settlement, he signed a stipulation and general release covering all liability, claims, and rights of action alleging civil-rights violations and related state-law claims against City officials, employees, representatives, and agents through November 1, 2024.
Motion and arguments
The defendants moved under Federal Rules of Civil Procedure 12(b)(6) and 12(c) to dismiss this case on the ground that the releases barred Urena’s claims. The court applied New York law and federal cases applying New York law to interpret the releases.
The court held that the release language was broad and clear. It rejected Urena’s argument that the releases were ambiguous, explaining that a provision stating the settlement could not be used in other litigation included an exception allowing enforcement of the agreement. The court also rejected his arguments that he may have unknowingly released pending claims, that the defendants knew about his other lawsuits, that the settlement consideration was inadequate, and that the prior judge did not sufficiently oversee the settlement.
Ruling
Judge Jesse M. Furman concluded that the releases covered Urena’s claims because they arose before November 1, 2024. Accordingly, the court granted the defendants’ motion to dismiss.
The court also declined to grant Urena leave to amend. It found that the defects were substantive and that amendment would be futile, noted that Urena had already received an opportunity to amend with a warning that he would not receive another opportunity, and observed that he had not identified additional facts that could cure the defects.
The Clerk was directed to enter judgment for the defendants, close the case, and mail the opinion and order to Urena. The court also certified under 18 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied Urena permission to appeal without paying filing fees.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.