Jones v. City Of New York

Background

Tracy Jones, represented by counsel, brought claims on behalf of her minor son, M.J., under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. She alleged that, on October 29, 2019, New York Police Department Officers Ryan Duffany and Charles Alexander used excessive force while arresting M.J. and that Alexander failed to intervene. The complaint alleged that Duffany kicked M.J.’s feet out from under him, lifted him by the arms, and slammed him head-first into the ground. It also asserted a municipal-liability claim against the City of New York.

The City and the Officer Defendants separately moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). That rule allows a party to seek judgment after the pleadings are closed, and the court applies the same standard used for a motion claiming that a complaint fails to state a legally sufficient claim.

The Release

The Defendants relied on a general release that Jones signed on December 30, 2021, after settling a separate case involving an alleged assault of M.J. by a New York City Administration of Child Services worker. Jones received $7,500 in that settlement. The release covered the City and its past and present officials, employees, and representatives, and released claims alleging violations of M.J.’s civil rights occurring before the release date.

Jones conceded that the release would bar the claims in this case if it were enforceable. She argued, however, that her lawyer had intended to include an exception for this already-pending case and had mistakenly failed to do so. She also argued that the release had not been reviewed for reasonableness in the separate case and that enforcement would not serve M.J.’s interests.

Court’s Analysis

The court held that the release was clear and unambiguous based on its text. It rejected the argument that counsel’s unexpressed intention to include an exception could change the written agreement. The court also held that signing the release on behalf of a minor did not make it unenforceable because the settlement had been approved by the court in the separate case.

The court explained that, although no formal infant-compromise order had been filed, the court in the separate case had granted counsel’s request to waive that requirement. The court therefore concluded that the release was enforceable and covered the claims against the City and the officers.

Disposition

Judge Swain granted the City’s and the Officer Defendants’ Motions for Judgment on the Pleadings in their entirety. The order resolved docket entries 74 and 78, directed the Clerk to enter judgment, and directed the Clerk to close the case. The court did not decide whether the alleged use of force violated M.J.’s constitutional rights; it ruled that the enforceable release barred the action.