Carlin v. City of New York

Background

Hunter Carlin sued the City of New York over his detention after his October 12, 2014 arrest. He alleged that he remained in the custody of the Department of Corrections for an unreasonable period after bail was paid. His claims included a claim under 42 U.S.C. § 1983, which provides a federal cause of action for certain violations of constitutional rights by government actors, and a false-imprisonment claim.

The opinion states that claims concerning Carlin’s detention at Bellevue Hospital under sections 9.27 and 9.39 of the New York Mental Hygiene Law were time-barred. The court therefore identified the remaining issue as whether Carlin was entitled to damages for an unreasonable delay between the posting of bail and his transfer out of Bellevue’s prison ward. The opinion also notes that the documentary record was incomplete because Carlin refused to sign a broad release of his medical records.

Settlement and Carlin’s Objections

During a July 29, 2025 conference, the parties reached a settlement in open court and placed its terms on the record. The City agreed to pay $30,000. One-third of that amount was designated as counsel’s fee, and the remaining $20,000 was to be paid to Carlin after the City’s payment was placed in counsel’s escrow account and cleared. In exchange, Carlin agreed to voluntarily dismiss the complaint. The agreement also included the City’s standard release, covering civil-rights claims from the beginning of time through the present, and stated that the City would not admit liability.

Carlin later asked the court not to enforce the settlement, citing what he called procedural and substantive concerns. He questioned whether his lawyer’s motion to withdraw affected the agreement and objected to the City’s choice of counsel at the conference. The court found that Carlin was represented when the City first made its settlement offer, that his lawyer’s withdrawal application did not invalidate the agreement, and that the conflict between Carlin and his lawyer had no actual impact on the settlement. The court also stated that Carlin had no standing to dictate which Corporation Counsel represented the City at the conference.

Ruling

Judge Naomi Reice Buchwald held that an oral settlement made on the record in open court is binding under New York law when it is voluntary, clear, explicit, and unqualified. A court may set such an agreement aside only for a contract-invalidating reason such as fraud, collusion, mistake, or accident. The court found none of those circumstances and stated that a change of mind was not enough.

The court enforced the parties’ binding settlement agreement. The opinion does not enter a merits ruling on whether Carlin’s detention violated federal or state law; instead, it resolves the matter by enforcing the settlement reached during the litigation.