Williams, Jr. v. City of New York

Background

Alexander Williams, Jr., representing himself, brought claims under 42 U.S.C. §§ 1983 and 1985 alleging that defendants violated his constitutional rights while he was held as a pretrial detainee at the George R. Vierno Center on Rikers Island. He asked the court to enter default judgments against Correction Officers Edmunds, Sharma, Omiblu, Emebu, Graves, and Coulthurst; ADW Carter; Captain Carter; and Dr. Blackmore. Williams argued that these defendants were not included in the defendants’ motion to dismiss, had not responded to the complaint, and did not appear to be represented by counsel.

Defendants’ counsel responded that CO Edmunds and ADW Carter were no longer parties or, as to Edmunds, had been dismissed. Counsel also stated that the remaining defendants may have been inadvertently omitted when the motion to dismiss was entered on the docket, but that all remaining defendants were listed in the notice of motion as represented by defense counsel and seeking dismissal.

Court’s analysis

Under Federal Rule of Civil Procedure 55(b)(2), a court may enter default judgment when a party fails to plead or otherwise defend. The court considered whether any failure was willful, whether the defendants had a potentially valid defense, and whether Williams would be harmed if default judgment were denied. The court emphasized that a good-faith mistake is not willful default, that courts generally prefer resolving disputes on their merits, and that default judgment is an extreme remedy.

The court held that default judgment was not appropriate against any listed defendant. ADW Carter had been terminated as a party in April 2021, so Williams’s request as to Carter failed as a matter of law. As to CO Edmunds, the court clarified that it had not dismissed him on its own initiative. Instead, the magistrate judge had issued a report and recommendation to Judge Paul G. Gardephe recommending dismissal, but Judge Gardephe had not yet ruled on it; therefore, Edmunds remained a party and should have appeared on the docket. For the other defendants, default was unwarranted because the notice of motion identified them as represented by defense counsel and as having moved to dismiss the action.

Disposition

Magistrate Judge Katharine H. Parker denied Williams’s request for default judgment. The Clerk of Court was directed to mail Williams a copy of the opinion. The opinion did not decide the merits of Williams’s underlying constitutional claims.