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S.D.N.Y.OtherFiled Jan. 14, 2022

Torres v. City Of New York

Judge
John Cronan
Docket
1:20-cv-10210
Court
U.S. District Court · Southern District of New York
Pages
2
Civil RightsCivil ProcedureClass Action
In one sentence

In Torres v. City of New York, Judge Cronan ordered the parties to brief whether plaintiffs have standing to pursue their seizure claim.

Who this affects

The named plaintiffs, the proposed class, and the defendants were affected because the court required the parties to address whether the plaintiffs personally had standing to bring the unreasonable-seizure claim.

What happened

In Torres v. City of New York, the plaintiffs claimed that the defendants violated their constitutional right to be free from unreasonable seizures. They said the proposed class included people whose property had been or might be seized to collect allegedly duplicative parking tickets.

The plaintiffs clarified that they were not claiming the tickets themselves were unreasonable seizures. They described possible seizures including wage garnishment, liens on real property, and restrictions on bank accounts. The opinion states that both plaintiffs had paid their two tickets and had not had property seized for failing to pay them.

Judge John P. Cronan did not decide the motion to dismiss. He ordered each side to file a letter addressing whether the plaintiffs personally suffered the concrete harm required to have standing to bring the claim.

The detailed version

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

Case
Torres v. City Of New York · No. 1:20-cv-10210
Judge
John Cronan
Date
Jan. 14, 2022

Background

The defendants moved to dismiss the plaintiffs’ First Amended Complaint. The plaintiffs alleged that the defendants deprived them of their constitutional right to be free from unreasonable seizures. They clarified that they were not arguing that the allegedly duplicative parking tickets themselves were unreasonable seizures.

Instead, the plaintiffs described a proposed class of people whose property had allegedly been seized, or was scheduled to be seized, because they failed to pay the allegedly duplicative tickets. The opinion identifies possible seizures as garnished wages, liens on real property, and restrictions on bank accounts.

Standing Question

The court noted that both named plaintiffs had paid their two parking tickets and had never had property seized for failing to pay them. The court therefore directed the parties to address whether the plaintiffs had standing—the legal requirement that a plaintiff personally show a concrete, particularized, actual or imminent injury that was caused by the defendants and could likely be remedied by a court.

Order

By January 21, 2022, each side had to file a letter of no more than five pages explaining how the plaintiffs were concretely harmed as alleged in the unreasonable-seizure claim. The opinion did not decide whether the plaintiffs had standing and did not state a disposition of the defendants’ motion to dismiss.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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