Williams v. Hernandez
- Lorna Schofield
- 1:20-cv-05995
- U.S. District Court · Southern District of New York
- 2
In Williams v. City of New York, Judge Schofield granted reconsideration after finding post-arrest evidence irrelevant to probable cause at arrest.
Garfield Anthony Williams and the defendants in the case, including the City of New York, Oscar Hernandez, and Joseph Ottaviano.
What happened
In Williams v. City of New York, the defendants had won summary judgment, and the court had ruled that Oscar Hernandez and Joseph Ottaviano had probable cause to arrest Garfield Anthony Williams for driving under the influence. Williams then asked the court to reconsider that decision.
Williams argued that information another driver gave Ottaviano came after the arrest. Although Ottaviano gave conflicting deposition testimony about when the conversation occurred, body-camera footage showed that it happened after the arrest. Because officers’ probable cause must be evaluated using information available at the time of arrest, the court found the information irrelevant to that issue.
Judge Lorna G. Schofield granted Williams’s motion for reconsideration. The court stated that it would issue an amended opinion that did not rely on the other driver’s statement when assessing probable cause, and directed the clerk to close the motion.
The detailed version
- Williams v. Hernandez · No. 1:20-cv-05995
- Lorna Schofield
- Mar. 17, 2023
Background
The defendants moved for summary judgment, a request for judgment without a trial when the moving party contends there is no genuine dispute requiring a trial. Williams moved for sanctions concerning two pieces of evidence. In an opinion issued March 1, 2023, the court granted the defendants’ summary-judgment motion and denied Williams’s sanctions motion. The court held that defendants Oscar Hernandez and Joseph Ottaviano had probable cause to arrest Williams for driving under the influence.
On March 14, 2023, Williams moved for reconsideration under Federal Rule of Civil Procedure 59(e) and Local Civil Rule 6.3. Reconsideration is an unusually strict form of review generally available when there has been a controlling change in law, new evidence, or a clear error or manifest injustice.
Reasoning
Williams argued that information provided by another driver was given to Ottaviano after Williams’s arrest. Ottaviano had given conflicting deposition testimony about the timing of the conversation. Body-camera footage submitted with the motions showed, however, that the conversation occurred after the arrest.
The court explained that probable cause at the time of arrest must be assessed using only facts available to the officer at the time of the arrest and immediately beforehand. Because the other driver’s statement came afterward, the court found it irrelevant to whether probable cause existed when Williams was arrested.
Ruling
Judge Lorna G. Schofield granted Williams’s motion for reconsideration. The court stated that it would issue an amended opinion that did not rely on the other driver’s statement to assess probable cause. The clerk was directed to close the motion at Docket No. 107. The order does not state the amended opinion’s ultimate disposition or whether the earlier summary-judgment ruling would change.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.