Amador v. City of New York

Background

Luis Amador originally sued the City of New York, the New York City Police Department, Detective Cruz M. Ramos, and several unidentified officers in Bronx County Supreme Court. He alleged violations of federal and state civil-rights laws arising from his arrest, imprisonment, and prosecution. Detective Ramos removed the case to federal court under the Westfall Act after the United States Attorney’s Office certified that Ramos had acted within the scope of federal employment as a deputized Drug Enforcement Administration task-force officer.

After the court denied Amador’s first motion to remand, Amador voluntarily dismissed every defendant except the City and continued only his New York malicious-prosecution claim. He also filed a separate federal lawsuit against the United States, the Drug Enforcement Administration, and DEA Agent Marlow Luna based on the same events. That separate case was proceeding before Judge P. Kevin Castel.

The parties’ arguments

Amador again moved to remand this case to state court. He argued that, because all federal claims and federal defendants had been dismissed, no basis remained for the federal court to retain supplemental jurisdiction over his state-law claim. Supplemental jurisdiction is a federal court’s discretionary authority to hear state-law claims connected to claims within its original federal jurisdiction.

The City opposed remand and cross-moved for summary judgment on the remaining claim. It argued that Amador was manipulating the forum by pursuing related claims in state and federal court and that the federal court should retain jurisdiction because the claims arose from a common set of facts. The City also argued that it could not be held vicariously liable for actions by NYPD officers deputized into federal service. Amador responded that other, non-deputized City employees were involved in his arrest and prosecution.

Court’s analysis

The court relied on 28 U.S.C. § 1367(c)(3), which permits a federal district court to decline supplemental jurisdiction after dismissing all claims over which it had original jurisdiction. The court noted that, ordinarily, judicial economy, convenience, fairness, and respect for state courts favor declining jurisdiction when only state-law claims remain.

The court found that all federal claims and federal defendants had been dismissed. The case was still in its early stages, no discovery had occurred in federal court, and the court had made no substantive findings on the merits. The remaining claim concerned state and municipal government. Although the City was correct that the state and federal claims arose from a common set of facts, the related federal claims were proceeding in a separate lawsuit before another federal judge. Keeping the state-law claim in this court therefore would not meaningfully promote judicial economy.

The court considered the City’s argument that Amador was seeking to litigate in his preferred forum. It concluded that, even taking that conduct into account, the alleged forum manipulation did not require the federal court to retain jurisdiction when the other factors favored remand.

Disposition

The court declined to exercise supplemental jurisdiction over the remaining state-law claim and granted Amador’s motion to remand the action to Supreme Court, Bronx County. It expressed no view on the merits of the City’s summary-judgment motion or on whether Amador’s malicious-prosecution claim was legally viable. The clerk was directed to terminate the pending motions, remand the action to New York State Supreme Court, and close the federal case.