Grogan v. New York University
- Laura Swain
- 1:20-cv-03345
- U.S. District Court · Southern District of New York
- 3
In Grogan v. New York University, Judge Wang denied or found moot several of Jared J. Grogan’s requests while reserving disability issues for later factfinding.
Jared J. Grogan, who was representing himself, and the defendants, New York University and NYU in Abu Dhabi Corporation.
What happened
In Grogan v. New York University, Jared J. Grogan, who was representing himself, raised several issues about his case, including his status, medical records, service, statements by the defendants, and possible sanctions. The court had already denied his request that the judge recuse herself.
The court found some requests moot because the docket already showed Grogan’s status, there were no pending requests for extensions, and the defendants had appeared and received notice of the lawsuit. It denied requests for emails, sanctions against the defendants, and relief concerning an allegedly false basis for a prior order. The court did not decide the nature or extent of Grogan’s disabilities or whether they caused an adverse employment action; it said those matters would be considered by a factfinder after discovery.
Judge Wang also cautioned Grogan that personal attacks on opposing counsel would not be tolerated. The order addressed the listed requests but did not resolve the underlying disability or employment issues.
The detailed version
- Grogan v. New York University · No. 1:20-cv-03345
- Laura Swain
- Oct. 23, 2023
Background
Jared J. Grogan, proceeding without a lawyer, filed a submission raising multiple issues and requests. The order followed the court’s October 12, 2023, denial of Grogan’s request for the judge’s recusal. Magistrate Judge Ona T. Wang addressed the remaining issues using Grogan’s numbering.
Rulings on the Requests
1. Pro se status and intake emails. The request to confirm Grogan’s status as a self-represented party was denied as moot because the docket and prior orders already reflected that status. The request for the court to retrieve emails Grogan sent to the pro se intake office was also denied.
2. Disability and injury descriptions. The court did not make factual findings about the nature or extent of Grogan’s disabilities or whether they were connected to an adverse employment action. It reserved those questions for a factfinder after discovery. Discovery had not yet begun.
3. Medical records. Grogan challenged an earlier directive requiring him to file medical documentation under seal to support explanations for tardy filings, an outdated mailing address, and missed conferences. The court explained that sealed medical records filed in that manner would be visible to the court and Grogan, while the public could see only that records had been filed. Because there were no outstanding extension requests or open dates for supplementing the complaint, the question whether Grogan had complied with the earlier directive was moot.
4. Redacted material. The court again treated Grogan’s descriptions of his injuries and disabilities as matters for a factfinder after discovery if they were relevant to his claims.
5. Alleged false statements. Grogan accused the defendants and their counsel of lying, withholding evidence, and misleading the court. The court said he had not identified the allegedly false assertions specifically enough to permit correction of the record. It also cautioned that personal attacks on opposing counsel would not be tolerated, even under the more flexible standards applied to self-represented parties.
6. Service of the lawsuit. Grogan blamed the defendants for difficulties serving them. The court found the issue moot because the defendants had appeared, participated in settlement discussions in good faith, and had notice of the lawsuit.
7. Sanctions against the defendants. The court denied the request for sanctions against the defendants.
8. Allegedly false basis for sanctions or a prior order. Grogan referred to a “provably false predicate,” but did not identify a docket order or filing establishing what he meant. The court stated that Grogan had received every extension he requested after indicating that he wished to supplement his complaint, including extensions requested after prior deadlines had passed. To the extent he sought amendment or vacatur—cancellation—of a prior order, the court denied that request.
9. Recusal-related items. Items 9 through 11 concerned Grogan’s recusal request, which the court had addressed in its October 12, 2023 ruling.
Disposition and Significance
The order denied or found moot several requests but did not decide the factual questions concerning Grogan’s disabilities or their connection to an adverse employment action. Those questions were left for possible consideration after discovery. The order was signed by Ona T. Wang, United States Magistrate Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.