O'Quinn v. City of New York
- Laura Swain
- 1:19-cv-09663
- U.S. District Court · Southern District of New York
- 8
In Carroll O’Quinn v. City of New York, Judge Swain briefly restored the case, retained jurisdiction to enforce the settlement, and dismissed it with prejudice.
Carroll O’Quinn and the City of New York are bound by the dismissal and settlement terms; the court retained authority to address enforcement of the settlement agreement.
What happened
Carroll O’Quinn asked the Southern District of New York to retain jurisdiction so the court could enforce his settlement with the City of New York. The settlement agreement provided for a $61,000 payment and resolved the claims without the City admitting fault or liability.
The court found that O’Quinn made the request within a reasonable time because he submitted it on the settlement deadline. It briefly restored the case to the docket so it could issue an amended dismissal order.
Judge Laura Taylor Swain retained jurisdiction to enforce the settlement agreement and ordered the action dismissed with prejudice and without costs to any party. The parties also had to submit a status report within 60 days about whether their dispute concerning the settlement payment had been resolved and whether court intervention was needed.
The detailed version
- O'Quinn v. City of New York · No. 1:19-cv-09663
- Laura Swain
- Jan. 12, 2024
Background
Carroll O’Quinn submitted a letter asking the court to retain jurisdiction—meaning continuing authority over the case—for purposes of enforcing the parties’ finalized settlement agreement. He attached the agreement. The City of New York opposed the request, and O’Quinn filed a reply.
The agreement stated that the action was settled and would be dismissed with prejudice. It provided that the City would pay O’Quinn a gross total of $61,000 for compensatory damages he alleged were for physical pain and suffering. The agreement stated that the payment resolved claims that had been or could have been alleged in the action, and that the settlement was not an admission of fault or liability.
Court’s Analysis
The parties’ stipulation of dismissal dismissed the underlying claims with prejudice, but it allowed O’Quinn to move for an order retaining jurisdiction to enforce the settlement. An earlier court order had also stated that the parties could ask the court to retain jurisdiction by submitting the settlement agreement for court approval.
The court construed that earlier provision as allowing the case to be reopened within a reasonable time so the dismissal order could be revised to incorporate the settlement agreement. Because O’Quinn filed his request and the agreement on December 14, 2023—the deadline for finalizing the settlement—the court concluded that the request was timely.
Disposition
The court ordered that the action be briefly restored to the docket so it could enter an amended order of dismissal. It expressly retained jurisdiction to enforce the parties’ settlement agreement, which was attached to the order. The court ordered the action dismissed with prejudice and without costs to any party. The parties were directed to submit a status report within 60 days stating whether their dispute concerning the settlement payment had been resolved and whether court intervention was needed.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.