Taylor v. Warden of the Manhattan Detention Center
- Alison Nathan
- 1:17-cv-07360
- U.S. District Court · Southern District of New York
- 2
In Taylor v. OBCC C.O. Nieves, Judge Nathan denied reconsideration and additional discovery, leaving the case closed.
Roy Taylor's motions were denied, and the defendants retained the earlier summary-judgment ruling in their favor; the case remains closed.
What happened
In Roy Taylor v. OBCC C.O. Nieves, et al., Taylor asked the court to reconsider its earlier decision granting summary judgment to the defendants. He also asked to add a witness and conduct more discovery.
Taylor argued that the video evidence was incomplete and that more discovery could show the facility was not under a total lockdown. The court said the video showed the pepper-spray incident from six angles and that undisputed evidence showed Taylor refused orders to return to his cell.
Judge Alison J. Nathan denied both motions. She concluded that Taylor identified no change in the law or new evidence, and that additional discovery would not affect the summary-judgment analysis. The case remains closed.
The detailed version
- Taylor v. Warden of the Manhattan Detention Center · No. 1:17-cv-07360
- Alison Nathan
- Dec. 15, 2020
Background
On November 30, 2020, the court granted summary judgment for the defendants and denied all other pending motions as moot. Summary judgment is a decision resolving a case without a trial when the evidence does not show a genuine dispute requiring a trial. Taylor then moved for reconsideration of that order and separately moved to add a witness and conduct further discovery.
Analysis
The court explained that reconsideration is an extraordinary remedy generally available only when the moving party identifies a change in controlling law, new evidence, or a clear error or manifest injustice. Taylor did not identify a change in law or new evidence. Instead, he repeated arguments the court had rejected in its November 30 order.
Taylor argued that the video evidence was incomplete, but the court found that the evidence was comprehensive and showed the pepper-spray incident from six different angles. The court also stated that Taylor's account in his summary-judgment opposition did not materially differ from the video.
Taylor sought additional discovery concerning whether the facility was under a total lockdown when the incident occurred and whether he should have been allowed to leave his cell to use the shower. The court found that the lockdown question was irrelevant to its summary-judgment analysis. It stated that undisputed evidence showed Taylor refused correctional officers' orders to return to his cell and that, regardless of whether those orders were reasonable or fair, the officers did not violate clearly established law by using pepper spray after less forceful measures failed.
Disposition
The court denied Taylor's motion for reconsideration, docket number 107, and denied his motion for further discovery, docket number 108. The court stated that the case remains closed. Judge Alison J. Nathan also directed the Clerk of Court to mail Taylor a copy of the order and record the mailing on the public docket.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.