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S.D.N.Y.Procedural orderFiled Aug. 25, 2023

Mulkern v. Lowe's Home Center, LLC

Judge
Laura Swain
Docket
1:23-cv-07362
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Mulkern v. Lowe's Home Center, LLC, Judge Swain dismissed the duplicate employment lawsuit without prejudice.

Who this affects

Kevin Mulkern's duplicate lawsuit was dismissed without prejudice; the pending related case was not dismissed by this order. Lowe's Home Center, LLC and Heather McClow were affected as defendants in the dismissed complaint.

What happened

Kevin Mulkern sued Lowe's Home Center, LLC without a lawyer, alleging claims related to the termination of his employment. The court said he had already filed a substantially similar case involving the same termination, which remains pending in the district.

The court dismissed this complaint without prejudice because it duplicated the pending lawsuit. It also explained that Mulkern could seek permission to add any claims against Heather McClow to the pending case if those claims arose from the same events. The court denied permission to appeal without paying filing fees, finding that an appeal would not be taken in good faith.

Judge Laura Taylor Swain entered the dismissal and directed that judgment be entered.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Mulkern v. Lowe's Home Center, LLC · No. 1:23-cv-07362
Judge
Laura Swain
Date
Aug. 25, 2023

Background

Kevin Mulkern brought the action without a lawyer, asserting claims under federal-question and diversity jurisdiction concerning the termination of his employment with Lowe's Home Center, LLC. The court stated that Mulkern had already brought a substantially similar action concerning the same termination. That earlier action was filed in state court, removed to the federal district court, and remained pending there under docket number 7:23-CV-3689 (KMK).

The complaint also listed Heather McClow as a defendant, but alleged only that she worked for Lowe's Home Center, LLC. The opinion did not identify any other allegations against her.

Ruling

The court dismissed the complaint without prejudice as duplicative of Mulkern's pending suit. The court stated that Mulkern could not pursue a duplicate lawsuit while the substantially similar case was pending. Regarding any claims against McClow arising from the same transaction, the court said Mulkern could seek permission to pursue those claims in the pending action under Rule 15 of the Federal Rules of Civil Procedure.

The court certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees. Judgment was ordered to be entered.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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