Williams v. City Derm
- Laura Swain
- 1:22-cv-00316
- U.S. District Court · Southern District of New York
- 4
In Williams v. City Derm, Judge Swain denied Earl Williams’s reconsideration motion because his appeal was pending and he showed no basis for relief.
Earl Williams, whose request to reconsider the dismissal of his lawsuit was denied; the case remains closed.
What happened
In Williams v. City Derm, Earl Williams asked the court to reconsider its earlier dismissal of his lawsuit against City Derm and other defendants. He had alleged that the defendants denied him medical treatment and discriminated against him.
The court had dismissed the lawsuit for failing to state a claim. It found that Williams had not shown a legal right to medical care from the defendants or facts showing they were state actors, and had not alleged discrimination based on a protected, unchangeable characteristic under federal law. Williams appealed, but the Second Circuit dismissed his appeal as lacking a reasonable basis in law or fact.
Judge Laura Taylor Swain denied Williams’s motion. She explained that the appeal was still pending and that, even under the procedure allowing the court to give an advisory ruling, Williams had not shown any reason for relief from the judgment. The case remains closed, and the court denied fee-free status for any appeal from this order.
The detailed version
- Williams v. City Derm · No. 1:22-cv-00316
- Laura Swain
- Oct. 13, 2022
Background
Earl Williams proceeded without a lawyer and without paying the filing fee. He alleged that City Derm and other defendants denied him medical treatment and discriminated against him. The court previously dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii), and judgment was entered on April 15, 2022.
The earlier dismissal found that Williams had not alleged a general right to medical care, facts showing that the defendants were state actors, or a special custodial or other relationship that could create a right to medical care. The court also found that he had not alleged facts suggesting discrimination based on an unchangeable characteristic, such as race, in violation of federal law.
Williams appealed the dismissal to the United States Court of Appeals for the Second Circuit. The Second Circuit dismissed the appeal because it lacked an arguable basis in law or fact. The Second Circuit later granted Williams additional time to seek reconsideration. Williams then filed a reconsideration motion and supporting declaration in the district court.
Court’s analysis
The district court treated Williams’s filings as a motion under Federal Rule of Civil Procedure 60(b), which permits relief from a judgment or order for specified reasons such as mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or other extraordinary circumstances.
The court first explained that filing a notice of appeal generally transfers authority over the appealed issues to the court of appeals. Because the district court had not received the appellate court’s mandate, it said it lacked authority to rule directly on Williams’s motion. The court nevertheless considered the motion under Federal Rule of Civil Procedure 62.1, which allows a district court to defer consideration, deny the motion, or state that it would grant the motion or that the motion raises a substantial issue if the court of appeals sends the matter back.
The court concluded that Williams had not shown that any of the first five grounds under Rule 60(b) applied or that extraordinary circumstances justified relief under the sixth ground. His motion repeated essentially the same facts and arguments that the court had previously found insufficient. The court therefore found no legal or factual basis to question its dismissal of the complaint.
Disposition
The court denied Williams’s motion for reconsideration. It terminated all other pending matters, treated the case as closed, and directed Williams to inform the Second Circuit of the order. The court also directed the clerk not to accept further filings under the closed case number except papers directed to the Second Circuit. Finally, it certified that an appeal from this order would not be taken in good faith and denied Williams fee-free status for purposes of such an appeal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.