Williams v. NYC Board of Elections
- Katharine Parker
- 1:23-cv-05460
- U.S. District Court · Southern District of New York
- 3
In Williams v. NYC Board of Elections, Judge Parker warned Williams about sanctions, denied email service, and ordered regular mail.
Carman Williams and the defendants’ counsel in this litigation; the order governs future communications, discovery-related conduct, and potential sanctions.
What happened
In Carman Williams v. NYC Board of Elections, et al., Defendants asked the court to require Williams to stop inappropriate conduct and accept discovery materials and filings by email.
The court said Williams had not cooperated with discovery, had missed a court-ordered conference, had not cooperated in scheduling her deposition, and had used insulting and threatening language toward defense counsel. Williams opposed email communication and said she would communicate only by mail.
The court granted Defendants’ motion insofar as it warned Williams that further abusive personal attacks could lead to sanctions, including dismissal. Judge Katharine H. Parker denied the request to require email service and directed Defendants to communicate with Williams by regular mail.
The detailed version
- Williams v. NYC Board of Elections · No. 1:23-cv-05460
- Katharine Parker
- May 23, 2024
Background
Defendants asked the court for an order requiring Plaintiff Carman Williams to stop inappropriate conduct and accept service of discovery materials and other filings by email. Williams opposed the request and stated that she did not want to communicate with defense counsel by email and would communicate only through mailed correspondence.
Court’s discussion
The court stated that Williams had refused to meet and confer with defense counsel about discovery, blocked defense counsel’s email, ignored requests, and said she would not read his emails. The court also stated that Williams had claimed not to receive documents sent by regular and certified mail, failed to attend a court-ordered conference on January 23, 2024, and failed to cooperate with efforts to schedule her deposition. The court had to set a deposition date at the courthouse.
The court further addressed an email in which Williams called defense counsel an “Uncle Tom” and a “self-hating” and “phenotypically black” person, and threatened to file a police report and grievance against him. Williams argued that she had a right to use that language and that her personal attacks were permissible because they did not occur in open court. The court rejected that position, stating that threatening and personally insulting language toward opposing counsel has no place in litigation. The opinion also states that Williams had previously informed the court that she is an attorney and that the conduct violated a New York professional-conduct rule concerning undignified or discourteous conduct.
Ruling
The court warned Williams that further conduct of the described kind would result in sanctions, up to and including dismissal of her action. It declined, however, to require Williams to accept service by email. The conclusion states that Defendants’ motion is GRANTED insofar as Williams was warned that she would be sanctioned if she engaged in further abusive personal attacks on defense counsel, and DENIED to the extent Defendants requested an order requiring her to accept email. Defendants were directed to communicate with Williams by regular U.S. mail. Judge Katharine H. Parker also directed the Clerk to mail Williams a copy of the order and terminate the motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.