Stapleton v. New York City Department of Education
- Paul Engelmayer
- 1:22-cv-09351
- U.S. District Court · Southern District of New York
- 3
In Stapleton v. New York City Department of Education, Judge Engelmayer dismissed Stapleton’s defamation claim and allowed her to amend her federal claims.
Katy Stapleton’s state-law defamation claim was dismissed, while she was allowed to amend her two federal retaliation claims. The defendants’ joint motion to dismiss was granted in part and denied in part.
What happened
In Stapleton v. New York City Department of Education, Katy Stapleton sued the New York City Department of Education and several coworkers. She claimed retaliation under the First Amendment and the Rehabilitation Act, and alleged defamation under state law.
The defendants asked the court to dismiss all of Stapleton’s claims. A magistrate judge recommended granting the request in part and denying it in part: dismissing the defamation claim while allowing Stapleton to amend her two federal claims.
Judge Engelmayer adopted that recommendation in full after finding no clear error and noting that no party objected. The court dismissed Stapleton’s defamation claim, granted her leave to amend the federal claims, and terminated the motion.
The detailed version
- Stapleton v. New York City Department of Education · No. 1:22-cv-09351
- Paul Engelmayer
- Sept. 21, 2023
Background
Katy Stapleton, identified as a Spanish teacher, sued the New York City Department of Education and coworkers Juan Villar, Bienvenida Galvez, Sofia Russo, Elizabeth Payero, Randall Chenevert, and Marilyn Ramirez. Her complaint asserted three claims: a First Amendment retaliation claim under 42 U.S.C. § 1983 against all defendants; a retaliation claim under the Rehabilitation Act against the Department of Education; and a state-law defamation claim against Ramirez.
The defendants filed a joint motion to dismiss all claims. The court had before it a Report and Recommendation by Magistrate Judge Stewart D. Aaron. The report recommended granting the motion in part and denying it in part, dismissing the defamation claim, and granting Stapleton leave to amend her two federal claims.
Court’s Analysis
Because no party objected to the Report and Recommendation, the district court reviewed it for clear error. Judge Engelmayer found no facial error in Judge Aaron’s conclusions and adopted the report in its entirety. The opinion incorporates the report’s factual summary rather than repeating those facts.
The court also stated that the parties’ failure to object waived objections and precluded appellate review, consistent with the warning in the Report and Recommendation.
Disposition
The court accepted and adopted Judge Aaron’s Report and Recommendation in its entirety. It dismissed Stapleton’s defamation claim and granted Stapleton leave to amend her federal claims. The court directed the Clerk to terminate the motion at docket 28, and the case remained under Judge Aaron’s pretrial supervision.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.