Hampshire Recreation, LLC v. the Village of Mamaroneck
664 F. App'x 98
| 2d Cir. | 2016Background
- Hampshire Recreation, LLC (Hampshire) operates a recreational property split between MR and R-20 zoning districts in the Village of Mamaroneck.
- Hampshire sought zoning relief and a special/permissive permit; the Village issued a probationary permit and later issued a violation notice and enforcement actions.
- Hampshire sued under 42 U.S.C. § 1983 asserting: (1) an Equal Protection selective-enforcement/class-of-one claim and (2) First Amendment retaliation for protected speech about rezoning.
- The District Court dismissed both federal claims under Rule 12(b)(6) for failure to state plausible claims, denied further amendment, and declined supplemental jurisdiction over state-law claims.
- Hampshire appealed; the Second Circuit reviewed the Rule 12(b)(6) dismissal de novo and affirmed the District Court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal Protection (selective enforcement / class-of-one) | Hampshire alleges it was treated differently from three other clubs and discriminated against. | Village argues Hampshire is not similarly situated because its property spans MR and R-20 zones and lacked an initial Special Permit. | Affirmed — Hampshire not similarly situated; Village’s permit decision not shown to be discriminatory. |
| First Amendment retaliation | Hampshire contends enforcement actions and violation notice were retaliation for its rezoning speech. | Village contends alleged enforcement was too remote in time and not plausibly retaliatory. | Affirmed — temporal gap (~18 months) and lack of other evidence defeat causal inference; claim dismissed. |
| Leave to amend | Hampshire requested further amendments after repeated deficiencies. | Village opposed amendment; trial court had discretion to deny. | Affirmed — District Court did not abuse discretion in denying leave to amend. |
| Supplemental jurisdiction over state claims | Hampshire wanted state-law claims retained in federal court. | District Court declined to exercise supplemental jurisdiction after dismissing federal claims. | Affirmed — District Court appropriately remanded state claims. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading under Rule 12(b)(6))
- Chase Grp. Alliance LLC v. N.Y.C. Dep't of Fin., 620 F.3d 146 (2d Cir. 2010) (standards for de novo review of Rule 12(b)(6) dismissal)
- Church of Am. Knights of the Ku Klux Klan v. Kerik, 356 F.3d 197 (2d Cir. 2004) (requirement to show similarly situated comparators in equal protection claims)
- Cifra v. Gen. Elec. Co., 252 F.3d 205 (2d Cir. 2001) (temporal proximity as evidence for causal connection in retaliation claims)
- Dougherty v. Town of North Hempstead BZA, 282 F.3d 83 (2d Cir. 2002) (First Amendment protects complaints to public officials and seeking administrative relief)