Lynch v. City Of New York
- Loretta Preska
- 1:16-cv-07355
- U.S. District Court · Southern District of New York
- 4
In Lynch v. City Of New York, Judge Preska denied Lynch’s request to reconsider refusing amendment and separating discovery on the Monell claim.
Mr. Lynch and the defendants, including the City of New York, Lombardo, and Paverman, were affected by the court’s refusal to reconsider the earlier amendment and discovery rulings.
What happened
In Lynch v. City Of New York, Mr. Lynch asked the court to reconsider an earlier order that denied permission to file an amended complaint and allowed discovery on the municipal-liability claim to be handled separately.
Mr. Lynch argued that the court had misunderstood instructions from the Court of Appeals and had wrongly found that proposed claims against Lombardo and Paverman would be futile. He also argued that separating discovery on the municipal-liability claim was an error because the facts overlapped with claims against individual defendants and could serve the public interest.
Judge Loretta A. Preska denied the motion for reconsideration. She concluded that the court had considered the relevant issues, that Mr. Lynch’s arguments showed only disagreement with its earlier decisions, and that the decision to separate discovery was not clearly erroneous.
The detailed version
- Lynch v. City Of New York · No. 1:16-cv-07355
- Loretta Preska
- Sept. 25, 2020
Background
Mr. Lynch moved for reconsideration of the court’s July 14, 2020 order. That earlier order denied his request for leave to file an amended complaint and granted the defendants’ request to bifurcate, or separate, discovery concerning the Monell claim. The opinion assumes the parties’ familiarity with the case’s facts and procedural history.
Arguments about the proposed amended complaint
Mr. Lynch argued that the court should reconsider its finding that allegations against Lombardo and Paverman in the proposed amended complaint would be futile. He asserted that the court had ignored instructions from the Court of Appeals and had clearly erred by failing to consider the allegations together as support for liability.
The court rejected both arguments. It said that, when denying leave to amend, it had considered the Court of Appeals’ conclusions that the claims against Lombardo failed because Mr. Lynch had not plausibly alleged Lombardo’s involvement in the alleged misconduct, and that the allegations against Paverman were conclusory and speculative. The court also said it had considered whether the proposed complaint corrected those problems and had concluded that it did not.
Arguments about separated discovery
Mr. Lynch also sought reconsideration of the decision to bifurcate discovery on the Monell claim. He argued that facts concerning the New York Police Department’s alleged “false observation practice” overlapped with the facts supporting claims against the individual defendants, that the Monell claim could survive even if the individual claims were dismissed, and that litigating the Monell claim could promote the public interest by exposing and addressing police misconduct.
The court concluded that these arguments reflected disagreement with its prior ruling and did not justify reconsideration. It stated that whether to bifurcate discovery was within its discretion and that it had followed the Second Circuit’s preference for bifurcating Monell claims in this case. The court found that decision was not clearly erroneous.
Standard and disposition
The court explained that reconsideration generally requires an intervening change in controlling law, new evidence, or a need to correct clear error or prevent manifest injustice. It also emphasized that reconsideration is not a way to relitigate issues already decided or obtain a rehearing.
Judge Loretta A. Preska denied Mr. Lynch’s motion for reconsideration and directed the Clerk of Court to close the open motion.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.