Mamatkulov v. City University of New York
- John Cronan
- 1:22-cv-04131
- U.S. District Court · Southern District of New York
- 5
In Mamatkulov v. City University, Judge Cronan denied reconsideration of dismissal and denied sealing the case because Plaintiff showed neither sufficient reason.
Lazizjon Mamatkulov’s earlier dismissal remains in place, and the court records he sought to seal remain subject to public access. City University of New York is the defendant named in the case.
What happened
Mamatkulov v. City University of New York concerns Lazizjon Mamatkulov’s request to undo the earlier dismissal of his amended complaint, which challenged his expulsion from Hunter College. He also asked the court to keep the case records from the public.
The court denied both requests. It found that Mamatkulov repeated his desire to return to Hunter College but provided no evidence or explanation showing that the earlier dismissal should be changed. The court also found that his reports of threats, ridicule, and online discussion of his expulsion did not overcome the strong public-access rule for court records.
Judge John P. Cronan left the earlier dismissal in place, denied the motion for reconsideration, and denied the motion to seal the case.
The detailed version
- Mamatkulov v. City University of New York · No. 1:22-cv-04131
- John Cronan
- Jan. 22, 2023
Background
On December 1, 2022, the Court dismissed Lazizjon Mamatkulov’s amended complaint, which challenged his expulsion from Hunter College. Mamatkulov then filed a motion asking the Court to reconsider that dismissal. He also asked the Court to seal the case so that its records would not appear on public websites. He said he had received threats and that students were making fun of him and using his expulsion against him.
Motion for Reconsideration
The Court treated Mamatkulov’s request as a motion under Federal Rule of Civil Procedure 59(e), which allows a party to ask a court to change or amend a judgment. The Court explained that reconsideration is an extraordinary remedy and generally requires an intervening change in controlling law, new evidence, or a need to correct a clear error or prevent serious unfairness.
The Court found that Mamatkulov did not meet that standard. His motion repeated that he wanted to be reinstated at Hunter College and requested a hearing, stating that he had evidence supporting his allegations. But he did not provide that evidence or explain how it would fix the problems in his amended complaint that the Court had previously identified. The Court therefore denied the motion for reconsideration.
Motion to Seal
The Court next considered Mamatkulov’s request to seal the case. It explained that court filings relevant to the judicial process are generally subject to a strong presumption of public access under the First Amendment and common law. Because Mamatkulov sought to seal all case records, the Court gave that presumption especially substantial weight. Sealing an entire case file is permitted only as a last resort, such as when required by law or justified by extraordinary circumstances and no narrower effective alternative exists.
The Court accepted Mamatkulov’s allegations but found that they did not overcome the public-access presumption. It noted that he did not describe the nature or seriousness of the threats or provide details about the people who were allegedly making fun of him and using his expulsion against him. The Court therefore denied the motion to seal.
Disposition
The Court denied both Mamatkulov’s motion for reconsideration and his motion to seal. The Clerk was directed to close the motion for reconsideration at Docket Number 12 and mail Mamatkulov a copy of the order. This order addressed the requests to reconsider the earlier dismissal and to seal the records; the opinion does not state the full basis for the earlier dismissal.
Classification
This is a procedural order because the Court denied reconsideration and denied a request to seal court records without deciding the underlying challenge to Mamatkulov’s expulsion.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.