Jones v. City Of New York
- George Daniels
- 1:18-cv-04064
- U.S. District Court · Southern District of New York
- 7
In Jones v. City of New York, Judge Parker granted Jones permission to amend his complaint to add an evidence-fabrication claim.
Henry Jones may add the proposed evidence-fabrication and fair-trial claim to his complaint. The defendants must address the amended pleading, and the City of New York and the individual officers remain affected by the case’s claims as described in the opinion.
What happened
Jones v. City of New York concerns Henry Jones’s arrest and prosecution for possessing a gun and ammunition after a 2016 shooting incident. Jones was acquitted by a jury and had originally sued over his arrest, imprisonment, and prosecution, including claims against the City of New York.
During discovery, Jones’s new lawyer asked to add a claim alleging that evidence was fabricated and that Jones was denied a fair trial. The defendants opposed the amendment mainly because of delay and sought to question Jones about the new claim. Jones also asked to drop the claims against Police Officer Morales.
Judge Katharine H. Parker granted Jones’s motion to amend. She found no undue delay or lack of diligence, no need for additional discovery, and no significant prejudice or delay to the defendants. The parties were ordered to agree on the final amended pleading, which Jones had to file by February 10, 2020.
The detailed version
- Jones v. City Of New York · No. 1:18-cv-04064
- George Daniels
- Feb. 6, 2020
Background
Henry Jones sued after his arrest and prosecution for possessing a gun and ammunition. The opinion states that Jones was arrested after running from a fight and shooting in the Bronx. Police Officer Ruben Serrano believed a gun found in grass belonged to Jones and reported that he had seen Jones with a gun and hand it to another person. Jones denied possessing the gun.
The opinion states that Police Officers Saul Quiles Morales and Sherrod Stuart did not see Jones with a gun. It also states that Stuart was shot by another police officer and that no physical evidence, such as DNA or fingerprints, connected Jones to the gun. Jones was detained for approximately 61 days while awaiting trial and was acquitted by a jury.
Jones originally asserted civil-rights claims for false arrest and imprisonment and malicious prosecution. He also asserted claims against the City of New York based on the actions of its employees. After Jones changed lawyers several times, his current lawyer asked to amend the complaint to add a claim alleging fabrication of evidence and deprivation of a fair trial, and to drop the claims against Morales.
Legal standard
Federal Rule of Civil Procedure 15 generally directs courts to freely allow amendments to pleadings when justice requires. Courts may deny leave to amend because of undue delay, bad faith, undue prejudice to the opposing party, or futility. Because a scheduling order deadline applied, the court also considered Rule 16, which requires good cause to modify that deadline. Good cause generally depends on whether the moving party acted diligently.
Court’s reasoning
The defendants’ main objection was delay. The court found that the proposed claim would not require additional discovery. It reasoned that Jones had no personal knowledge about the factual basis of the fabrication claim beyond testimony he had already given, and that reopening his deposition would not produce new information.
The court also found that Jones’s new counsel acted promptly after deposing Officer Stuart. The court accepted counsel’s position that the deposition newly strengthened the basis for the proposed claim. It further found that counsel had quickly become familiar with the case, complied with discovery obligations, and actively participated in discovery.
The court noted that no trial had been scheduled and that summary-judgment briefing had not begun. It therefore found no basis to conclude that the amendment would delay resolution of the case or unfairly prejudice the defendants.
Ruling
Judge Katharine H. Parker granted Jones’s motion to amend. The parties were directed to meet and confer about the final version of the amended pleading, and Jones was ordered to file the amended complaint electronically by February 10, 2020. The opinion resolves the request to amend; it does not decide whether Jones’s proposed evidence-fabrication or other claims ultimately succeed.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.