Snead v. Lobianco
- Denise Cote
- 1:16-cv-09528
- U.S. District Court · Southern District of New York
- 6
In Snead v. LoBianco, Judge Nathan denied defendants’ request to reconsider an earlier summary-judgment ruling involving Snead’s fair-trial and malicious-prosecution claims.
The ruling affected the defendants’ effort to obtain dismissal of Snead’s remaining fair-trial and malicious-prosecution claims. Those claims were not dismissed through this order and remained governed by the earlier summary-judgment ruling.
What happened
In Snead v. LoBianco, the defendants asked the court to reconsider an earlier ruling on summary judgment, a procedure for deciding claims when no important factual dispute requires a trial. They asked the court to dismiss Lisa Snead’s remaining fair-trial and malicious-prosecution claims.
The court declined to reconsider the fair-trial claims because the defendants were raising arguments that they had not made in their earlier summary-judgment motion. As to malicious prosecution, the court said a prior decision did not automatically establish that Snead’s speedy-trial dismissal was unfavorable to her. The court also found an important factual dispute about whether the criminal case was dismissed because of Snead’s innocence and insufficient evidence.
Judge Alison J. Nathan denied the defendants’ motion for reconsideration. The earlier ruling therefore remained in place, including the survival of Snead’s remaining claims.
The detailed version
- Snead v. Lobianco · No. 1:16-cv-09528
- Denise Cote
- Mar. 8, 2021
Background
The defendants moved under Southern District of New York Local Civil Rule 6.3 for reconsideration of the court’s May 28, 2020 ruling on the parties’ partial summary-judgment motions. In that earlier ruling, the court denied Snead’s motion for summary judgment on her claims under 42 U.S.C. § 1983 and granted the defendants’ motion in part and denied it in part. Snead had withdrawn her fair-trial and malicious-prosecution claims against Officer Hanson and her fair-trial claim against Sergeant Barnes; the earlier opinion dismissed those claims with prejudice. Her fair-trial claim against Officer LoBianco and malicious-prosecution claims against the remaining defendants survived.
Fair-Trial Claims
The defendants asked the court to dismiss Snead’s remaining fair-trial claims based on what they characterized as a change in controlling law, relying on the Supreme Court’s decision in McDonough v. Smith. The court held that this argument was not properly presented through reconsideration because the defendants had not moved for summary judgment on those claims in the original motion. A reconsideration motion could not be used to assert the arguments for the first time.
Malicious-Prosecution Claims
The defendants also argued that the malicious-prosecution claims should be dismissed under Lanning v. City of Glens Falls. The court acknowledged that it had not addressed the defendants’ supplemental letter making that argument, but explained that reconsideration still required the defendants to show that considering the material would have changed the earlier decision.
The court concluded that Lanning did not automatically resolve whether Snead’s criminal case, which was dismissed on speedy-trial grounds, ended in her favor. It stated that a factual determination was required regarding whether the dismissal reflected Snead’s innocence. The court also found a genuine dispute of material fact under Rule 56 about whether the prosecution stopped because prosecutors recognized Snead’s innocence and lacked sufficient evidence. For that reason, summary judgment would have been improper even if the supplemental argument had been considered earlier.
Disposition
The court denied the defendants’ motion for reconsideration and stated that the ruling resolved docket entry 145. The opinion was signed by Alison J. Nathan, United States District Judge, on March 8, 2021.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.