Taylor v. City of New York Administration for Children Services and Kim Taylor
Stanley Taylor v. City of New York Administration for Children Services and Kim Taylor
- Laura Swain
- 1:17-cv-05522
- U.S. District Court · Southern District of New York
- 2
In Stanley Taylor v. City of New York Administration for Children Services, Judge Swain denied Taylor’s motion to vacate an earlier dismissal.
Stanley Taylor’s attempt to vacate the 2021 dismissal was rejected; the order left that dismissal in place.
What happened
In Stanley Taylor v. City of New York Administration for Children Services and Kim Taylor, Stanley Taylor asked the court to undo its 2021 dismissal of his amended complaint. The earlier dismissal relied on the conclusion that his claims were barred by issues decided in an earlier proceeding.
Taylor argued that the court had incorrectly applied rules preventing the relitigation of claims or issues, because the earlier proceeding allegedly could not decide his retaliation, discrimination, and federal constitutional claims. The court rejected that argument, referring to its reasons in the 2021 decision.
The court also ruled that Taylor waited too long to file the motion and gave no explanation for the delay. Judge Swain denied the motion under Federal Rule of Civil Procedure 60 and directed the Clerk of Court to mail Taylor a copy of the order.
The detailed version
- Taylor v. City of New York Administration for Children Services and Kim Taylor · No. 1:17-cv-05522
- Laura Swain
- July 15, 2026
Background
Pro se plaintiff Stanley Taylor moved under Federal Rule of Civil Procedure 60(b)(4) to vacate the court’s March 30, 2021, memorandum opinion and order. That earlier order dismissed Taylor’s amended complaint based on collateral estoppel, a rule that can prevent a party from relitigating an issue already decided in an earlier proceeding.
Taylor argued that the 2021 dismissal incorrectly applied res judicata and collateral estoppel based on an earlier proceeding under Article 78 of New York’s Civil Practice Law and Rules. He asserted that the earlier proceeding lacked jurisdiction over retaliation, discrimination, and federal constitutional claims.
Court’s Analysis
The court rejected Taylor’s argument for the reasons stated in its 2021 memorandum opinion and order. The court also cited the principle that a judgment in an Article 78 proceeding can prevent relitigation of issues already decided in that judgment.
The court separately held that the motion was untimely. Rule 60(c)(1) requires a Rule 60 motion to be made within a reasonable time. Citing a 2026 Supreme Court decision, the court stated that this reasonable-time requirement applies even to a motion alleging that a judgment is void under Rule 60(b)(4). Taylor filed his motion more than five years after the challenged judgment and offered no explanation for the delay. The court found no other circumstances justifying the prolonged delay.
Disposition
The court denied Taylor’s motion. The order resolved docket entry number 65 and directed the Clerk of Court to mail a copy of the order to Taylor and record service on the docket.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.