Doe v. The Trustee of Columbia University in The City of New York
- Edgardo Ramos
- 1:21-cv-05839
- U.S. District Court · Southern District of New York
- 3
In Doe v. Trustees of Columbia University, Judge Ramos explained that discovery remains stayed and Doe’s proposed default and summary-judgment motions were premature.
Jane Doe and the defendants are affected: discovery remains stayed, the defendants’ motion to dismiss remains pending, and Doe’s proposed default-judgment and summary-judgment motions were not appropriate at that stage.
What happened
In Doe v. The Trustees of Columbia University in the City of New York, Jane Doe, who was representing herself, asked the court to clarify an earlier order. That order had stayed discovery while the defendants’ request to dismiss the case was pending and had denied her request for permission to seek default judgment or summary judgment.
The court explained that discovery could be paused because responding would be burdensome in this Title IX case, which involved sensitive subject matter and privacy concerns. It also said the defendants had not failed to defend the case because their deadline was stayed under the court’s procedures while they sought permission to file their dismissal motion. A default judgment request therefore was not appropriate, and a summary-judgment request was premature because discovery was stayed and the dismissal motion was pending.
Judge Edgardo Ramos maintained the discovery stay and explained why Doe’s proposed default-judgment and summary-judgment motions were not appropriate at that stage. The opinion did not decide the defendants’ pending request to dismiss the case.
The detailed version
- Doe v. The Trustee of Columbia University in The City of New York · No. 1:21-cv-05839
- Edgardo Ramos
- Sept. 16, 2021
Background
Jane Doe, proceeding without a lawyer, requested clarification of the Court’s September 15, 2021 order. That earlier order had stayed discovery while the defendants’ motion to dismiss was pending and denied Doe’s request for leave to file a motion for default judgment or summary judgment.
The defendants were The Trustees of Columbia University in the City of New York, Kevin Pitt, Alyssa Anzalone-Newman, and Kristin Collado. The opinion describes the case as involving Title IX and sensitive subject matter. It also states that the parties had participated in settlement discussions and a settlement conference, but the settlement conference was unsuccessful.
Discovery stay
The Court explained that Federal Rule of Civil Procedure 26(c) allows discovery to be stayed for good cause. It applied factors concerning whether the defendant had strongly shown that the claim was unmeritorious, the breadth and burden of discovery, and the risk of unfair prejudice to the party opposing the stay.
The Court emphasized that discovery would be burdensome because the case involved sensitive subject matter and required protections for the privacy of parties and non-parties. It also found no risk of unfair prejudice to Doe, noting that her amended complaint had been filed six weeks earlier and that the parties had been engaged in settlement negotiations. The opinion therefore clarified the basis for keeping discovery stayed while the motion to dismiss was pending.
Default judgment
Default judgment is a judgment entered when a party seeking affirmative relief has failed to plead or otherwise defend, as required by Federal Rule of Civil Procedure 55(a). The Court concluded that this had not occurred.
The defendants had sent a pre-motion letter on August 5, 2021, seeking permission to file a motion to dismiss. Under the Court’s individual practices, that request stayed the deadline for the defendants to file a motion or answer until a new deadline was set. After the parties attended an unsuccessful settlement conference, both sides asked the Court to set deadlines for the motion to dismiss, and the Court adopted the defendants’ proposed briefing schedule. The Court stated that the defendants had not failed to plead or otherwise defend, so Doe’s proposed default-judgment motion was not appropriate.
Summary judgment
Federal Rule of Civil Procedure 56(b) permits a summary-judgment motion to be filed at any time, but the Court explained that such a motion may be denied as premature when discovery on relevant matters is incomplete or the opposing party has not had time to file a responsive pleading. Here, discovery was stayed and the defendants’ motion to dismiss remained pending. The Court therefore determined that a summary-judgment motion was premature.
Disposition
The order clarified and maintained the earlier discovery stay and explained why Doe’s proposed motions for default judgment and summary judgment were not appropriate at that stage. The opinion did not decide the merits of the Title IX claims or the defendants’ pending motion to dismiss.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.