Singleton v. The People of the State of New York
- Louis Stanton
- 1:20-cv-04686
- U.S. District Court · Southern District of New York
- 4
In Singleton v. The People of New York, Judge Stanton denied motions seeking to change or reconsider the earlier dismissal.
Aaron Singleton’s postjudgment requests were denied, the action remained closed, and further filings under this docket number were barred except papers directed to the United States Court of Appeals for the Second Circuit.
What happened
Aaron Singleton, representing himself, submitted evidence, two requests to amend his complaint, and a supporting declaration after the court dismissed his action on August 20, 2020. He also filed a notice of appeal.
The court treated the four submissions, but not the notice of appeal, as requests to change the judgment or reconsider the dismissal. Because those requests arrived within the 28-day deadline, the court concluded it could decide them even though the appeal was pending.
Judge Louis L. Stanton denied the requests because Singleton did not show that the court had overlooked a controlling legal decision or important facts previously presented. The court closed the matter, terminated two motions, and directed the Clerk to accept no further filings under this docket number except papers for the federal appeals court.
The detailed version
- Singleton v. The People of the State of New York · No. 1:20-cv-04686
- Louis Stanton
- Oct. 14, 2020
Background
The court had previously dismissed Aaron Singleton’s self-represented action by an order and judgment dated August 20, 2020, and entered on August 21, 2020. After that judgment, Singleton submitted a document labeled “evidence,” two motions asking for permission to file an amended complaint, and a declaration supporting one of those motions. He also filed a notice of appeal.
Jurisdiction
The court treated the evidence submission, the two amendment motions, and the supporting declaration as motions under Federal Rule of Civil Procedure 59(e), which allows a party to ask the district court to change or amend a judgment, and under Local Civil Rule 6.3, which governs reconsideration in that court. The court did not treat the notice of appeal as one of those motions.
The judgment was entered on August 21, 2020, so the 28-day deadline for a Rule 59(e) motion was September 18, 2020. The court received all four submissions by that date. It therefore concluded that the motions were timely and that it retained authority to decide them even though Singleton had filed a notice of appeal on September 10, 2020.
Legal standard and ruling
The court stated that the standards for a Rule 59(e) motion and a Local Civil Rule 6.3 reconsideration motion are the same. The person seeking relief must show that the court overlooked controlling legal decisions or factual matters that had already been presented. These motions are narrowly applied and cannot be used simply to repeat arguments, introduce new theories, or present new evidence in response to the court’s decision.
The court found that Singleton had not made the required showing and therefore denied relief under both Rule 59(e) and Local Civil Rule 6.3. The court directed the Clerk to terminate the two amendment motions, mail Singleton a copy of the order, and accept no further submissions from him under this docket number except papers directed to the United States Court of Appeals for the Second Circuit. The order also stated that any civil-rights or detention-relief claims concerning his present confinement would have to be brought in a separate civil action, because this action was closed.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.