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S.D.N.Y.Procedural orderFiled May 14, 2020

Coleman v. The State of Officer John Doe

Judge
Louis Stanton
Docket
1:20-cv-02146
Court
U.S. District Court · Southern District of New York
Pages
8
Civil ProcedureMotion to Dismiss
In one sentence

In David Coleman v. The State of New York Police Department, Judge Stanton granted Coleman 30 more days to file an amended complaint.

Who this affects

David Coleman, whose deadline to file an amended complaint was extended by 30 days; the unidentified individuals he might later name as defendants were also addressed by the order.

What happened

David Coleman v. The State of New York Police Department concerns Coleman’s request for more time to amend his complaint. The court had previously allowed him to proceed without paying filing fees but found that his original complaint did not state a claim and gave him 60 days to amend it.

Coleman asked for an extension because he received the earlier order late and was waiting for arrest records and officer names requested under New York’s Freedom of Information Law. The court also explained that he could use John Doe or Jane Doe labels for unidentified defendants if he described what each person allegedly did.

The court granted a 30-day extension, and Judge Louis L. Stanton stated that Coleman could file an amended complaint within 30 days of the order. The court also warned that naming unidentified defendants would not pause the three-year limitations period mentioned in the order.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Coleman v. The State of Officer John Doe · No. 1:20-cv-02146
Judge
Louis Stanton
Date
May 14, 2020

Background

In an earlier order dated March 19, 2020, the court granted David Coleman permission to proceed without prepaying filing fees but held that his complaint failed to state a claim on which relief could be granted. The court gave him 60 days to file an amended complaint.

On May 14, 2020, the court received Coleman’s letter requesting additional time. Coleman stated that he did not receive the earlier order until March 30, 2020. He also said that he had requested his arrest records and the names of the officers involved in his arrest under New York’s Freedom of Information Law, but had not yet received them.

Court’s Ruling

The court granted Coleman’s request for a 30-day extension to file an amended complaint. If he chose to amend, the court ordered him to do so within 30 days of the May 14 order.

The court explained that Coleman could identify unknown defendants as “John Doe #1” or “Jane Doe #1” in the amended complaint’s caption. He would need to explain in the complaint what each unidentified defendant did or failed to do that allegedly violated his rights. The court stated that, if the amended allegations stated a claim and provided enough information, it might direct the New York City Law Department to identify the defendants’ true names.

The order also stated that using John Doe names would not pause the three-year limitations period governing the action. Coleman remained responsible for finding the defendants’ identities and amending the complaint to include their identities before that period expired.

Disposition

The court granted the request for a 30-day extension. This order addressed the filing deadline and amendment process; it did not decide whether Coleman’s claims ultimately had legal merit.

The authoritative version

Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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