McKinley v. Detective Kyle Crevatas

Background

Mark McKinley brought a civil-rights lawsuit under 42 U.S.C. § 1983 against Detective Kyle Crevatas, Detective Logan Payano, Officer Edgar Garcia, Detective Sean Brown, and NYPD Undercover Officer UC 376. McKinley alleged that the officers violated the Fourth, Fifth, Sixth, and Fourteenth Amendments during and after his March 27, 2018 arrest. According to the Fourth Amended Complaint, the officers tackled, struck, searched, handcuffed, and transported him, and Detective Brown performed a cavity inspection. McKinley also alleged that the officers initiated a criminal prosecution based on false allegations. The criminal charges were dismissed on August 2, 2018.

McKinley had separately resolved an earlier related proceeding involving injuries he allegedly suffered while incarcerated at Rikers Island. As part of that settlement, he signed a general release in exchange for $25,000. The release covered the City of New York and various related individuals and entities and referred broadly to state and federal claims arising from matters, causes, or things occurring through the release date. The release’s exclusions section was left blank.

Motion and conversion

The defendants initially moved for judgment on the pleadings, arguing that the general release barred McKinley’s claims. Because both sides submitted documents outside the pleadings, including the settlement documents, McKinley’s declaration, and a stipulation of discontinuance, the court converted the motion into one for summary judgment under Federal Rule of Civil Procedure 12(d). The court gave McKinley notice of the conversion and an opportunity to provide additional material; he chose to rely on his existing submissions.

Summary judgment is appropriate only when there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. When a contract is ambiguous, meaning it reasonably can be read in more than one way, the court may consider evidence outside the document to determine the parties’ intent.

The release

The defendants argued that the phrase “above-stated” modified only “matter,” so that the release covered claims arising from any cause or thing occurring before the release was signed. Under that reading, the release would cover the claims arising from McKinley’s arrest. McKinley argued that “above-stated” could modify the entire phrase “matters, causes, or things,” limiting the release to matters connected to the earlier related proceeding.

The court held that it could not reject either interpretation as a matter of law. It therefore found the release ambiguous. The court also concluded that the outside evidence did not resolve the ambiguity in the defendants’ favor. McKinley submitted a declaration stating that no one told him the settlement could affect his federal civil-rights lawsuit against the officers. The court said that statement was not conclusive, but it also found that the other settlement documents did not support the defendants’ preferred broad interpretation.

Disposition

The court found a genuine dispute of material fact about whether the general release covered McKinley’s federal civil-rights claims. It denied the defendants’ motion for summary judgment. The parties were directed to submit a joint status letter and a revised proposed case-management plan by July 6, 2022, and the clerk was directed to terminate the pending motion. Judge Katherine Polk Failla did not grant summary judgment to the defendants based on the release.