Aponte v. City of New York
- Kenneth Karas
- 7:14-cv-03989
- U.S. District Court · Southern District of New York
- 3
In Aponte v. City of New York, Judge Karas left the $1 nominal-damages judgment undisturbed after reviewing Aponte’s late filing.
Felix Aponte, whose $1 nominal-damages judgment remains in place, and the defendants, who face no additional damages under the claims discussed in this order.
What happened
Aponte v. City of New York followed the court’s earlier decision partially granting and partially denying the defendants’ motion for summary judgment. The court had required Felix Aponte to explain why he deserved more than $1 for any actual injury during a two-week period of unconstitutional detention.
Aponte’s response was late, but the court reviewed it because he was representing himself. The court found that his references to the injustice of the detention and generalized mental and emotional suffering did not show an actual injury. It also said he could not recover damages on his false-imprisonment claim because that claim had already been dismissed based on privileged confinement.
Judge Kenneth M. Karas concluded that the $1 judgment was appropriate, left it undisturbed, and kept the case closed.
The detailed version
- Aponte v. City of New York · No. 7:14-cv-03989
- Kenneth Karas
- June 4, 2020
Background
On April 20, 2020, the court partially granted and partially denied the defendants’ motion for summary judgment. The court directed Felix Aponte to submit, within 30 days, an explanation of whether and why he was entitled to more than $1 in nominal damages for any actual injury during a two-week period of unconstitutional detention. The opinion and order was mailed to the address listed for Aponte.
Aponte did not make a timely submission. The court therefore entered judgment for $1 in nominal damages on May 27, 2020, closed the case, and the Clerk entered judgment that day. The court later received Aponte’s filing, which was postmarked May 21 and attempted to address the possible compensatory damages. The court reviewed the filing despite its lateness because Aponte was representing himself.
Court’s Analysis
The court concluded that the filing did not show an entitlement to more than nominal damages. Aponte again referred to the injustice of the unconstitutional detention and to generalized mental and emotional suffering, but the court found that he had not alleged an actual injury during the relevant two-week period.
The court explained that damages based only on the abstract importance of constitutional rights are not compensatory damages in cases brought under 42 U.S.C. § 1983. When a constitutional violation causes no proven actual injury, nominal damages—not damages based on an undefined value of the right—are the appropriate remedy.
The court also addressed Aponte’s apparent request for damages for false imprisonment. It stated that the false-imprisonment claim had been dismissed as a matter of law in the earlier opinion and order because the detention was privileged. Aponte therefore could not recover damages under that claim.
Disposition
Judge Kenneth M. Karas concluded that the judgment for $1 in nominal damages was appropriate. The case remained closed, and the judgment was not disturbed. The order did not revisit or change the earlier summary-judgment dispositions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.