Singleton v. City Of New York

Background

Dwayne Singleton sued the City of New York, Joel Torres, and John or Jane Doe 1-10, identified as New York City police officers sued individually and in their official capacities. He asserted claims under 42 U.S.C. §§ 1981, 1983, 1985, 1986, and 1988 based on alleged police conduct during his May 10, 2019 arrest. Singleton alleged that officers targeted him because of race, religion, national origin, ethnicity, or other improper characteristics; tackled him without justification; searched and arrested him unlawfully; and caused injuries requiring treatment at Harlem Hospital. He also alleged that he was incarcerated for five days and that the criminal charges were later dismissed.

Separately, Singleton had filed a claim with the New York City Comptroller concerning an October 22, 2019 incident. He signed a General Release on February 12, 2020, to resolve that claim. The release broadly discharged the City and its officials, officers, employees, agents, and other covered persons from civil-rights claims and other claims based on matters occurring through the date of the release, subject to an expressly listed exception.

Motion and Legal Standard

The defendants moved for summary judgment, which is a request for judgment without a trial because the evidence shows no genuine dispute about a fact that could affect the result. Singleton did not file an opposition by the court-ordered deadline. The court nevertheless explained that it had to independently review the record and determine whether the defendants’ factual statements were supported by evidence and whether their legal theory was sound.

The court treated the defendants’ statements of material fact as admitted under Local Civil Rule 56.1. It then reviewed the General Release and applied contract-law principles, explaining that clear release language must be enforced according to the parties’ expressed intent and that broad language is construed against the person who signed the release.

Court’s Analysis

The court found the General Release plain, unambiguous, and broad. It covered civil-rights claims and other claims arising from incidents occurring through February 12, 2020. The release did not expressly exclude the May 10, 2019 incident. The court noted that the release did expressly identify an exception for a different incident, which indicated that an exception for the May incident would have been stated if intended.

Because Singleton’s claims in this case concerned events occurring between May 10, 2019, and August 16, 2019, the court held that those claims were barred by the February 2020 General Release. The court concluded that the defendants’ legal theory was sound and that they were entitled to summary judgment.

Disposition

Judge Oetken granted the defendants’ motion for summary judgment. The court directed the Clerk of Court to close the motion at Docket Number 31, enter judgment in favor of the defendants, and close the case.