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S.D.N.Y.Procedural orderFiled Nov. 20, 2020

Bromfield v. Bronx Lebanon Special Care Center, Inc.

Judge
Sarah Cave
Docket
1:16-cv-10047
Court
U.S. District Court · Southern District of New York
Pages
3
Civil ProcedurePro Se
In one sentence

In Bromfield v. Bronx Lebanon, Judge Cave vacated pro bono counsel’s appointment after Lenora Bromfield did not respond to potential counsel.

Who this affects

Lenora Bromfield’s previously authorized volunteer legal representation for settlement negotiations was ended. The order also directed the Clerk of Court to mail Bromfield a copy of the order.

What happened

In Bromfield v. Bronx Lebanon Special Care Center, Inc., the court had previously directed the Clerk to seek a volunteer lawyer for Lenora Bromfield, who was representing herself, to assist only with settlement negotiations.

The court said potential volunteer lawyers had reported that Bromfield was not responding to their outreach. It also considered the limited supply of volunteer lawyers and the demands created by the COVID-19 pandemic.

Judge Sarah L. Cave vacated the earlier order appointing pro bono counsel. The order did not decide the underlying claims.

The detailed version

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

Case
Bromfield v. Bronx Lebanon Special Care Center, Inc. · No. 1:16-cv-10047
Judge
Sarah Cave
Date
Nov. 20, 2020

Background

On August 6, 2020, the court directed the Clerk of Court to seek pro bono counsel— a volunteer lawyer—to assist pro se plaintiff Lenora Bromfield with settlement negotiations only. The court had limited the representation because the COVID-19 pandemic had reduced the already limited availability of volunteer lawyers. The August 6 order also stated that, until a volunteer lawyer was found, Bromfield could seek assistance from the New York Legal Assistance Group.

Bromfield later moved for reconsideration of the August 6 order. The opinion says that motion would be addressed in due course. Bromfield also renewed her request for pro bono counsel on October 15, 2020; the court denied that request as duplicative of the reconsideration motion.

Reason for the ruling

The court was informed that Bromfield had not responded to outreach from potential pro bono counsel. The court considered the limited number of volunteer lawyers, the effects of the COVID-19 pandemic, and the need to conserve judicial resources. It cited decisions addressing the withdrawal or denial of volunteer counsel when a plaintiff does not cooperate with counsel.

Disposition

Judge Sarah L. Cave vacated the order appointing pro bono counsel, identified as ECF No. 162. The Clerk of Court was directed to mail a copy of the order to Bromfield. The opinion does not state that the underlying action or claims were dismissed.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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