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S.D.N.Y.Procedural orderFiled Sept. 30, 2022

Citizens United To Protect Our Neighborhoods v. Village of Chestnut Ridge

Full caption

Citizens United To Protect Our Neighborhoods v. Village of Chestnut Ridge, New York

Judge
Nelson Roman
Docket
7:19-cv-03461
Court
U.S. District Court · Southern District of New York
Pages
1
Civil ProcedureMotion to Dismiss
In one sentence

In Citizens United v. Village of Chestnut Ridge, Judge Roman granted dismissal, denied intervention as moot, and dismissed plaintiffs’ complaint without prejudice for lack of jurisdiction.

Who this affects

The plaintiffs’ complaint was dismissed without prejudice; the Village of Chestnut Ridge, New York, received judgment in its favor; and the proposed intervenors’ motion to intervene was denied as moot.

What happened

In Citizens United To Protect Our Neighborhoods v. Village of Chestnut Ridge, New York, the plaintiffs sued the Village of Chestnut Ridge, New York. The judgment states that the court’s earlier opinion and order provided the reasons for its decision.

The court granted the defendant’s motion to dismiss. It dismissed the plaintiffs’ complaint without prejudice for lack of subject-matter jurisdiction, explaining that the dismissal was based on the plaintiffs’ lack of standing under Article III of the Constitution. The court also denied the proposed intervenors’ motion to intervene as moot.

Judge Nelson Roman’s judgment entered judgment in favor of the Village of Chestnut Ridge, New York, without prejudice. The judgment was dated September 30, 2022.

The detailed version

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

Case
Citizens United To Protect Our Neighborhoods v. Village of Chestnut Ridge · No. 7:19-cv-03461
Judge
Nelson Roman
Date
Sept. 30, 2022

Ruling

The judgment states that, for the reasons in the court’s Opinion and Order dated September 30, 2022, the defendant’s motion to dismiss was granted. The plaintiffs’ complaint was dismissed without prejudice for lack of subject-matter jurisdiction.

The judgment identifies the jurisdictional problem as the plaintiffs’ lack of standing under Article III. Standing is the requirement that a plaintiff have a sufficient personal stake in a dispute for a federal court to decide it. The judgment cites Second Circuit law stating that a dismissal for lack of Article III standing cannot be entered with prejudice and instead must be without prejudice.

Other Motion

The proposed intervenors’ motion to intervene was denied as moot. The judgment does not provide further details about the proposed intervenors or the arguments made in either motion.

Disposition

Judgment was entered in favor of the Village of Chestnut Ridge, New York, without prejudice. Because the case was dismissed for lack of subject-matter jurisdiction without reaching the underlying dispute, this is a procedural ruling.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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