Monahan v. City of New York
- P. Castel
- 1:20-cv-02610
- U.S. District Court · Southern District of New York
- 2
In Monahan v. City of New York, Judge Castel ordered briefing on whether to decline jurisdiction over the remaining state false-arrest claim.
The plaintiffs and the City of New York were required to address whether the federal court should continue hearing the remaining state-law false-arrest claim.
What happened
In Monahan v. City of New York, the plaintiffs brought a federal civil-rights claim against New York City and a separate false-arrest claim.
The court said the first claim was based on a federal civil-rights law and municipal-liability principles, and that the court had already dismissed it on summary judgment. The court interpreted the second claim as a state-law false-arrest claim against the City, even though its title referred to the Fourth Amendment.
Judge Castel ordered the parties to explain within 14 days why the court should not decline to continue hearing the remaining state-law claim. The order did not itself dispose of that claim.
The detailed version
- Monahan v. City of New York · No. 1:20-cv-02610
- P. Castel
- Apr. 7, 2022
Claims and prior ruling
The plaintiffs’ first claim was expressly identified as a claim under 42 U.S.C. § 1983, a federal civil-rights statute. The complaint also alleged that the City maintained a policy, which the court said implicitly invoked the municipal-liability standard from Monell. In an Opinion and Order dated March 30, 2022, the court granted summary judgment to the City on that claim and dismissed it.
The plaintiffs’ second claim was titled “FALSE ARREST (IN VIOLATION OF THE FOURTH AMENDMENT).” The court noted that this claim did not invoke § 1983 or the Monell standard. It construed the claim instead as a state-law false-arrest claim against the City under a theory that an employer may be responsible for an employee’s actions. The court stated that it could hear this state-law claim through supplemental jurisdiction, which allows a federal court to hear certain related state-law claims.
Order
Because the plaintiffs’ only federal claim had been dismissed, the court directed the parties to show cause in writing within 14 days why it should not decline to exercise supplemental jurisdiction over the remaining state-law false-arrest claim. The order did not state that the court had dismissed, granted judgment on, or otherwise finally resolved that remaining claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.