Owens v. N.Y.C. Department of Sanitation

Background

Darnell Owens, representing himself, filed this action in 2011 against the New York City Department of Sanitation (DSNY) and the Uniformed Sanitation Men’s Association, International Brotherhood of Teamsters Local 831 (Local 831). He alleged gender and race discrimination, retaliation, and constructive discharge under Title VII of the Civil Rights Act of 1964.

In 2013, the court dismissed all claims against Local 831 with prejudice. The court also dismissed Owens’s gender-discrimination, retaliation, and constructive-discharge claims against DSNY, leaving a racial-discrimination claim. In 2015, the court granted DSNY’s motion for summary judgment on that remaining claim, and the clerk closed the case.

Owens filed three requests to reopen the case in 2016, all of which the court denied. In 2025 and 2026, he filed additional requests. His latest filings alleged that his mother or other family members interfered with his case, attempted to take or ruin a settlement offer, or made motions without his knowledge. He also referred to a matter involving the New York City Comptroller.

Legal standard

The court treated Owens’s request as a motion under Federal Rule of Civil Procedure 60(b), which permits a court to relieve a party from a judgment for specified reasons. Motions under Rules 60(b)(1) through (3) must be filed within one year after the judgment. Because the summary judgment was entered on March 6, 2015, and Owens’s first request to reopen was received on August 10, 2016, the court held that those grounds were time-barred.

The court found that Owens had not alleged facts showing that Rules 60(b)(4) or (5) applied. It therefore considered the request under Rule 60(b)(6), a provision covering other reasons that could justify relief. Relief under that provision requires extraordinary circumstances supported by highly convincing material.

Court’s analysis

The court found that Owens had not provided highly convincing evidence that family members made fraudulent appearances or motions on his behalf. His assertion that his mother made motions without his knowledge was unsupported by the record, and he did not identify which motions were allegedly fraudulent.

The court also found that Owens had not plausibly shown that the New York City Law Department made a settlement offer or explained how such an offer would justify reopening the case. The court stated that, if a settlement offer had concerned this case, negotiations had failed before DSNY moved for summary judgment. If the alleged offer concerned another case, Owens had not shown how that matter related to this action.

Finally, the court found that Owens had not plausibly shown any connection between the New York City Comptroller and the subject matter of this case.

Disposition

The court denied Owens’s motion. It directed the clerk to terminate the pending motions at ECF Nos. 96 and 100, keep the case closed, and mail the opinion to Owens at the most recent address listed on the docket.