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S.D.N.Y.Procedural orderFiled Dec. 29, 2020

Phoenix Light SF Limited v. The Bank of New York Mellon Corporation

Judge
Valerie Caproni
Docket
1:14-cv-10104
Court
U.S. District Court · Southern District of New York
Pages
3
Civil ProcedureSummary Judgment
In one sentence

In Phoenix Light SF Limited v. The Bank of New York Mellon, Judge Caproni ordered plaintiffs to explain why the case should not be stayed pending a related appeal.

Who this affects

Phoenix Light SF Limited and the other plaintiffs, The Bank of New York Mellon as Trustee, and the related matter at Docket No. 18-CV-1194 were affected because the parties were ordered to brief whether the cases should be stayed pending the Second Circuit appeal.

What happened

Phoenix Light SF Limited and other plaintiffs sued The Bank of New York Mellon over breach-of-contract claims involving underlying agreements. The court was considering the defendant’s second motion for summary judgment.

A judge in a related case involving many of the same plaintiffs ruled that they lacked the legal requirements—constitutional and prudential standing—to bring their contract claims. That ruling was on appeal, and Judge Caproni anticipated that the appeal could resolve whether the plaintiffs had standing in this case.

Judge Valerie Caproni did not stay the case or decide the summary-judgment motion. Instead, she ordered the plaintiffs to explain by January 8, 2021, why this case and a related matter should not be stayed while the appeal was pending; the defendant could respond by January 15, 2021.

The detailed version

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

Case
Phoenix Light SF Limited v. The Bank of New York Mellon Corporation · No. 1:14-cv-10104
Judge
Valerie Caproni
Date
Dec. 29, 2020

Background

The plaintiffs brought breach-of-contract claims against The Bank of New York Mellon, as Trustee. The defendant had a second motion for summary judgment pending before Judge Caproni. The court had also permitted the defendant to file a supplemental brief addressing whether the plaintiffs lacked standing—the legal requirement that a plaintiff be entitled to bring a claim—and, alternatively, whether a prior related decision prevented the plaintiffs from arguing that they had standing.

Related proceeding and appeal

In a related case involving many of the same plaintiffs and the same underlying agreements, Judge Vernon S. Broderick granted the defendant’s motion for summary judgment. He found that the plaintiffs lacked both constitutional and prudential standing to bring their breach-of-contract action. The plaintiffs appealed and later filed a motion asking Judge Broderick to reconsider; he denied that motion. The appeal remained pending before the U.S. Court of Appeals for the Second Circuit.

Court’s action

Judge Caproni stated that, based on her review of the related decision and the appellate brief, she anticipated that the Second Circuit’s ruling would resolve whether the plaintiffs in this case had Article III standing to bring their claims. The court therefore ordered the plaintiffs to show cause—meaning explain why the requested action should not be taken—by January 8, 2021, why this case and the related matter at Docket No. 18-CV-1194 should not be stayed while the appeal was pending. The defendant had until January 15, 2021, to respond. Each side could submit a letter of up to eight double-spaced pages. The order did not itself stay the cases and did not rule on the pending summary-judgment motion.

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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