Gaffney v. Muhammad Ali Enterprises LLC
- George Daniels
- 1:18-cv-08770
- U.S. District Court · Southern District of New York
- 2
In Gaffney v. Muhammad Ali Enterprises LLC, Judge Daniels granted reconsideration and denied Defendants’ motion in limine after a Supreme Court ruling changed controlling law.
Michael Gaffney and the defendants in the two related actions. The ruling changes whether Gaffney may offer evidence or argument about alleged damages incurred more than three years before he filed the relevant claims.
What happened
In Gaffney v. Muhammad Ali Enterprises LLC, the court had previously barred Michael Gaffney from offering evidence or argument about damages incurred more than three years before he filed the relevant claims.
The court had left open the possibility of restoring those claims if the Supreme Court reversed the Second Circuit’s decision in Sohm v. Scholastic Inc. After the Supreme Court abrogated Sohm on May 9, 2024, Gaffney moved for reconsideration. The motion was unopposed.
Judge George B. Daniels granted Gaffney’s motion for reconsideration and denied Defendants’ Motion in Limine No. 1. The clerk was directed to close the related motions.
The detailed version
- Gaffney v. Muhammad Ali Enterprises LLC · No. 1:18-cv-08770
- George Daniels
- May 23, 2024
Background
On February 27, 2024, the court granted Defendants’ Motion in Limine No. 1. A motion in limine asks the court to decide before trial whether certain evidence or arguments may be presented. The earlier order precluded Michael Gaffney from offering evidence or argument about alleged damages incurred more than three years before he filed the relevant claims. The court had stated that the claims could be restored if the Supreme Court reversed the Second Circuit’s decision in Sohm v. Scholastic Inc.
Change in Controlling Law
On May 9, 2024, the Supreme Court abrogated Sohm. In this context, that meant the Supreme Court’s decision displaced the legal rule from that earlier Second Circuit decision. Gaffney then moved, without opposition, for reconsideration of the court’s ruling on Motion in Limine No. 1.
Ruling
The court granted Gaffney’s motion for reconsideration and denied Defendants’ Motion in Limine No. 1. The court relied on an intervening change in controlling law as a major ground supporting reconsideration. The clerk was directed to close the motion at ECF No. 284 in 18-cv-8770 and the motion at ECF No. 165 in 20-cv-7113.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.