Goodman v. The City of New York
- Clarke
- 1:23-cv-09648
- U.S. District Court · Southern District of New York
- 2
In Jason Goodman v. City of New York, Judge Clarke denied contempt sanctions over a nonparty’s brief and left the case closed.
The ruling denied Jason Goodman’s request for contempt sanctions against non-party David G. Sweigert and left the case closed.
What happened
In Jason Goodman v. The City of New York, et al., Jason Goodman, representing himself, asked the court to hold David G. Sweigert in contempt for filing a brief in the case. The case had already been dismissed and was on appeal.
The court said that contempt power must be used cautiously. It concluded that filing the two-page brief did not justify sanctions because the alleged violation was minor and Mr. Sweigert was not a party to the case.
Judge Jessica G. L. Clarke vacated an earlier order that had denied the motion for a filing-rule violation and then denied Goodman’s contempt motion. The case remains closed.
The detailed version
- Goodman v. The City of New York · No. 1:23-cv-09648
- Clarke
- Sept. 10, 2025
Background
Jason Goodman filed the action representing himself and alleged violations of his First Amendment rights under federal and state laws. The court had previously adopted a magistrate judge’s recommendation that the defendants’ motions to dismiss be granted and the case dismissed. The court later denied Goodman’s motion seeking reconsideration and relief from the judgment.
Contempt Motion
On August 26, 2025, Goodman moved to hold non-party David G. Sweigert in contempt and sought related relief, based on a purported two-page outside-party brief that Mr. Sweigert filed. Goodman argued that the filing violated a magistrate judge’s order disallowing such filings. A magistrate judge initially denied the motion because it did not comply with that judge’s individual motion rules.
Because the motion was directed to Judge Clarke and complied with her motion rules, Judge Clarke vacated the earlier order and considered the motion herself.
Court’s Reasoning and Ruling
The court explained that courts have inherent authority to punish contempt, but must exercise that authority cautiously and with restraint. It determined that the alleged contempt did not warrant sanctions. The court relied on the minor nature of filing the two-page brief, as well as the fact that the person alleged to be in contempt was not a party to the case, which was already closed and on appeal.
Judge Clarke denied Goodman’s motion. The court directed the clerk to vacate the earlier order, enter the order denying the contempt motion, and serve a copy on Goodman. The case remains closed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.