Doe v. Columbia University
- Gregory Woods
- 1:20-cv-06770
- U.S. District Court · Southern District of New York
- 1
Judge Woods ordered the parties in Doe v. Columbia University to provide an article that the amended complaint repeatedly relies on.
The parties, John Doe and Columbia University, were ordered to provide the court with the Bwog article or submit any objections by the specified deadlines.
What happened
In Doe v. Columbia University, the court considered what materials it could review when evaluating a motion to dismiss for failure to state a claim. The amended complaint repeatedly relied on an article posted on the Bwog website on February 6, 2018.
The parties had not provided the article to the court. Because the complaint appeared to depend heavily on the article’s contents and effects, the court determined that the article appeared to be an important part of the complaint.
Judge Gregory H. Woods ordered the parties to provide the court with a copy of the article by September 21, 2022. Any objections had to be submitted by September 20, 2022. The order did not decide whether the complaint stated a valid claim.
The detailed version
- Doe v. Columbia University · No. 1:20-cv-06770
- Gregory Woods
- Sept. 18, 2022
Background The plaintiff’s amended complaint repeatedly relied on the terms and effects of an article posted on the Bwog website on February 6, 2018. The opinion identified several portions of the amended complaint that referred to the article. The parties had not provided the article to the court.
Legal standard When deciding a motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), a court generally may consider the complaint, documents attached to it, and documents incorporated into it. The court may also consider a document not formally incorporated when the complaint relies heavily on the document’s terms and effects, making the document integral to the complaint.
Order The court stated that the Bwog article appeared to be integral to the amended complaint. It ordered the parties to provide the court with a copy of the article no later than September 21, 2022. Any objections to the request had to be submitted no later than September 20, 2022. This order did not decide the merits of the claims or whether the amended complaint stated a valid claim.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.