Daniels v. City of New York
- Ronnie Abrams
- 1:18-cv-03717
- U.S. District Court · Southern District of New York
- 1
In Daniels v. City of New York, Judge Abrams ordered briefing on how a Supreme Court decision affects Daniels’s fair-trial claim.
Deshawn Daniels and the four defendants were required to address the court’s questions in supplemental briefs; the order also affects the handling of Daniels’s § 1983 fair-trial claim.
What happened
In Daniels v. City of New York, Deshawn Daniels brought a civil-rights claim under federal law against four New York detectives and a sergeant. The order does not describe the underlying facts or decide the claim.
The court ordered both sides to file supplemental briefs of no more than ten pages by February 19, 2020. The briefs must address whether a favorable termination is required for a fair-trial claim and whether an adjournment in contemplation of dismissal can satisfy that requirement.
Judge Ronnie Abrams issued the order on February 5, 2020. The order only required additional briefing and did not rule on the merits of Daniels’s claim.
The detailed version
- Daniels v. City of New York · No. 1:18-cv-03717
- Ronnie Abrams
- Feb. 5, 2020
Background
Deshawn Daniels sued Detective Brian Taylor, Detective James Cleary, Sergeant Wesley Fradera, and Detective Neil Magliano. The order refers to Daniels’s claim under 42 U.S.C. § 1983, a federal civil-rights statute, alleging that his right to a fair trial was violated. The opinion does not provide the underlying facts of the claim.
Order
The court required the parties to submit supplemental briefing by February 19, 2020. Each side’s brief could not exceed ten pages.
The parties were directed to discuss two questions concerning the Supreme Court’s decision in McDonough v. Smith, 139 S. Ct. 2149 (2019):
1. Whether McDonough establishes that a favorable termination is an element of a § 1983 fair-trial claim. 2. If a favorable termination is required, whether an adjournment in contemplation of dismissal qualifies as a favorable termination for a fair-trial claim, even if it does not qualify as one for a malicious-prosecution claim.
The court also directed the parties to discuss an Eastern District of New York decision addressing the second question.
Disposition
Judge Ronnie Abrams issued an order requiring supplemental briefing. The order did not decide whether a favorable termination is required, whether the adjournment qualifies as a favorable termination, or whether Daniels’s fair-trial claim succeeds.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.