Hall v. NYC Water Board
1:24-cv-02483
S.D.N.Y.Nov 7, 2024Background
- Plaintiff Anthony Winston Hall brought a breach of contract action against the New York City Water Board, naming the Board, its Chief Financial Officer Joseph Murin, and unnamed agents, successors, and assigns as defendants.
- The case was referred to Magistrate Judge Gabriel W. Gorenstein for pretrial matters and a Report and Recommendation concerning a dispositive motion (a motion to dismiss).
- The Water Board moved to dismiss the action for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1).
- Judge Gorenstein recommended that the motion to dismiss be granted and that the case be dismissed without prejudice.
- The parties were informed they had fourteen days to object to the Report and Recommendation; no objections were filed.
- Judge Cronan conducted a de novo review, adopted the recommendation, and issued an order dismissing the case without prejudice.
Issues
| Issue | Hall's Argument | Water Board's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction | The federal court has jurisdiction over his breach of contract claim. | The court lacks subject matter jurisdiction over the contract dispute. | Court lacks subject matter jurisdiction; case dismissed without prejudice. |
| Waiver of Objections | (None expressly stated by Plaintiff) | No objections filed; recommendation stands. | No objections considered; right to object/appellate review waived. |
| Merit of Interpleader Disbursement Motion | Plaintiff is entitled to $40 million in relief. | (Not specifically addressed apart from jurisdiction.) | Court lacks jurisdiction; motion rejected as wholly without merit. |
| Appeal In Forma Pauperis | (Not raised by Plaintiff) | (Not raised by Defendant) | Appeal not taken in good faith; in forma pauperis status denied. |
Key Cases Cited
- United States v. Male Juvenile, 121 F.3d 34 (2d Cir. 1997) (establishes standard for district court review of magistrate's report and recommendations)
- Frank v. Johnson, 968 F.2d 298 (2d Cir. 1992) (failure to object waives right to appellate review)
- Caidor v. Onondaga County, 517 F.3d 601 (2d Cir. 2008) (reiterates effect of failure to object to report and recommendation)
- Coppedge v. United States, 369 U.S. 438 (1962) (standard for in forma pauperis appeals: good faith requirement)