Morgan v. United Federation of Teachers
- Lewis Kaplan
- 1:23-cv-00697
- U.S. District Court · Southern District of New York
- 2
In Morgan v. United Federation of Teachers, Judge Lewis A. Kaplan granted defendants’ motions to dismiss, dismissing federal claims with prejudice and state claims without prejudice.
Anthony Morgan’s federal and state-law claims against United Federation of Teachers and the other defendants. The federal claims were dismissed with prejudice, while the state-law claims were dismissed without prejudice for lack of exercised jurisdiction.
What happened
Anthony Morgan objected to a magistrate judge’s recommendation that the defendants’ motions to dismiss be granted. He argued that the recommendation relied on outdated law and overlooked an inaccurate statement by the Department of Education about an investigation.
The court rejected those arguments. It held that the Second Circuit decisions concerning random, unauthorized acts and established state procedures remained valid, and agreed that the alleged inaccurate statement was a random, unauthorized act for which a state Article 78 proceeding would have provided an adequate remedy.
Judge Lewis A. Kaplan granted the defendants’ motions to dismiss. The federal claims were dismissed on the merits and with prejudice; the state-law claims were dismissed without prejudice because the court declined to exercise jurisdiction over them, and the case was closed.
The detailed version
- Morgan v. United Federation of Teachers · No. 1:23-cv-00697
- Lewis Kaplan
- June 28, 2023
Background
Anthony Morgan objected to a June 7, 2023 report and recommendation by Magistrate Judge Stewart D. Aaron. The report recommended granting the defendants’ motions to dismiss the complaint. Morgan’s first objection concerned his procedural-due-process allegations. He argued that the recommendation improperly relied on cases based on Parratt v. Taylor, which he claimed had been entirely overruled by Daniels v. Williams. He also argued that the report overlooked an allegation that someone acting for the Department of Education made an inaccurate statement at an evidentiary hearing by saying that an investigation was still pending even though it had ended.
Court’s Analysis
The court rejected Morgan’s argument about Parratt. It explained that the Second Circuit decisions cited in the report remained authoritative concerning the procedural-due-process distinction between random and unauthorized acts and the use of established state procedures. According to the court, Daniels overruled Parratt only to the extent that Parratt treated a state official’s mere lack of due care as a deprivation of life, liberty, or property under the Fourteenth Amendment.
The court also concluded that the report had not ignored Morgan’s allegation about the Department of Education’s statement. After separating the allegation from Morgan’s conclusory descriptions, the court agreed that any inaccurate statement was a random and unauthorized act. The complaint did not support an inference that the statement was anything else. The court further agreed that a proceeding under Article 78 of New York law would have provided a fully adequate remedy for any constitutional violation.
Disposition
Judge Lewis A. Kaplan granted the defendants’ motions to dismiss the complaint and dismissed the case. The dismissal was on the merits and with prejudice as to the federal claims for relief. It was without prejudice as to the state-law claims because the court declined to exercise jurisdiction over them. The clerk was directed to close the case.
Classification Note
This is classified as a procedural order because the court resolved the matter through motions to dismiss, a threshold pleading procedure, even though the order stated that the dismissal of the federal claims was on the merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.