Taylor v. Trigeno
- Gregory Woods
- 1:16-cv-01143
- U.S. District Court · Southern District of New York
- 4
In Taylor v. City of New York, Judge Woods denied Taylor’s reconsideration motion and denied permission to appeal without paying filing fees.
Roy Joaquin Taylor’s request to reconsider the earlier sanctions ruling was denied. The court also denied him permission to appeal this order without paying filing fees. The order addressed the City of New York and officers involved in opposing the motion, including Officer Quayyum and Officer Trigeno.
What happened
In Roy Joaquin Taylor v. City of New York, et al., Taylor, who represented himself, asked the court to reconsider its earlier denial of sanctions concerning Officer Quayyum’s discovery response. Taylor argued that the response about Quayyum’s prior use of chemical spray was evasive.
The court found that Taylor identified no new or overlooked law or facts that would change its earlier decision. It also found the motion untimely because it was filed almost two months after the earlier order, beyond the 14-day deadline, and because fact discovery had ended more than two years earlier.
Judge Gregory H. Woods denied Taylor’s motion for reconsideration. The court also denied Taylor permission to appeal without paying filing fees, finding that any appeal would not be taken in good faith.
The detailed version
- Taylor v. Trigeno · No. 1:16-cv-01143
- Gregory Woods
- Mar. 5, 2024
Background
Roy Joaquin Taylor, proceeding without a lawyer, previously moved for sanctions against counsel for Officer Quayyum. Taylor alleged that Quayyum had falsely answered “no” to an interrogatory asking whether Quayyum had ever been involved in using a chemical agent against another detainee. The defendants disputed Taylor’s characterization of the interrogatory and response, while acknowledging that the record showed Quayyum had used chemical-agent spray against another inmate. The court denied Taylor’s sanctions motion on December 26, 2023.
Taylor then filed a motion objecting to that decision and requesting monetary penalties for what he described as current and future evasiveness. The court treated the filing as a motion for reconsideration. The City of New York and Officer Trigeno opposed it as an improper reconsideration motion, although the dispute described in the opinion concerned Officer Quayyum’s discovery response.
Legal standard
Under Federal Rule of Civil Procedure 60(b), a court may provide relief from a final order for specified reasons, including mistake, newly discovered evidence, fraud or misrepresentation, or another reason justifying relief. Southern District of New York Local Rule 6.3 permits a party to seek reconsideration or reargument within 14 days of an order. Reconsideration is an extraordinary remedy and generally requires showing that the court overlooked controlling law or facts that could reasonably change its conclusion. A party may not use reconsideration simply to relitigate an issue already decided.
Courts must read filings by people without lawyers generously, but those litigants still must comply with procedural and substantive rules.
Court’s analysis
The court liberally construed Taylor’s motion but found no legal or factual error in the December 26 order. Taylor argued that Quayyum should have answered the interrogatory directly instead of objecting to it. The court concluded that Taylor had not identified any new or overlooked law, facts, or other details affecting the earlier analysis or conclusion.
The court also held that the motion was untimely. Taylor filed it almost two months after the December 26 order, well beyond Local Rule 6.3’s 14-day period. The court separately found that Taylor’s discovery objections were untimely because fact discovery had ended on January 14, 2022, and the court had already ruled on the defendants’ summary-judgment motion arising from the events involving Officer Quayyum.
Disposition
Judge Gregory H. Woods denied Taylor’s motion for reconsideration. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied Taylor permission to appeal without paying filing fees. The clerk was directed to terminate the motion at Docket Number 290 and mail Taylor a copy of the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.