Lloyd Jones, et al. v. The City of New York

Background

The court considered a motion by Daryl Stephen, who was representing himself, to reconsider the court’s April 28, 2025 order. That earlier order denied Stephen’s application to participate in the class settlement in this case because the court found that he did not meet the settlement class definition. Stephen also moved to compel the City to produce documents that he said would support reconsideration.

The settlement class included people who were in Department of Correction custody, were released from that custody upon payment of bail during the relevant period, and experienced a delay in release after bail was paid. The court had previously found that, on two occasions, Stephen was not released after bail was paid because a court-ordered surety examination had to occur first.

Reconsideration standards and timeliness

The court explained that reconsideration is an extraordinary remedy and that the party seeking it has a heavy burden. Under Rule 59(e) of the Federal Rules of Civil Procedure, a motion to alter or amend a judgment generally must be filed within 28 days. The court concluded that Rule 59 was not the correct rule for Stephen’s request and noted that he filed it about three months after the April 28 order.

The court also considered the request under Rule 60(b)(1), which permits relief from a final order because of mistake, inadvertence, surprise, or excusable neglect. A motion under that provision must be filed within one year. The court found that Stephen’s motion was timely under Rule 60(b)(1). Stephen also stated that he had not received the April 28 order by mail and learned about it only after contacting the court’s Pro Se Intake Unit and obtaining a copy from the courthouse.

Court’s analysis

Stephen argued that the settlement definition did not exclude people subject to surety examinations and did not distinguish between types of bail. He asserted that he had shown that he was held in Department of Correction custody, posted bail, and experienced a delay in release. He also argued that excluding surety-examination delays created unequal treatment between people whose release delays were described as processing delays and those whose delays involved surety examinations.

The court rejected that interpretation. It read the settlement class definition as covering only people who could be released upon payment of bail. Because the Department of Correction could not release Stephen after he posted bail until he completed a surety examination, the court concluded that he was not released from custody “upon payment of Bail” as required by the settlement definition.

The court stated that this interpretation was not arbitrary because it followed the definition agreed to by the parties and certified by the court. The court added that if Stephen experienced a release delay after posting bail and completing the surety examination, that claim was not among the claims settled in this lawsuit. The court emphasized that its ruling was limited to determining that the claim Stephen sought to bring was not the type of claim covered by the settlement in Jones.

Ruling

Judge John G. Koeltl found that Stephen had not shown an intervening change in controlling law, new evidence, clear error, or manifest injustice. The court therefore denied Stephen’s motion for reconsideration. It also denied his motion to compel the City to produce records as moot. The clerk was directed to close the docket entries for the two motions and mail Stephen a copy of the order.