Kraft v. City of New York, 441 F. App'x 24

Kraft sued the City of New York and HHC medical personnel under §1983 and state law for involuntary hospitalization.
District court granted summary judgment to the defendants, ruling in their favor on all claims.
Kraft, proceeding pro se, appealed the district court’s grant of summary judgment and the denial of reconsideration.
The Second Circuit reviews summary judgment de novo and denial of reconsideration for abuse of discretion.
The panel affirming relied on the district court’s reasoning and record, noting Kraft’s arguments were largely rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is a genuine dispute of material fact on Kraft's §1983 claims.	Kraft asserts violations by hospital staff and clinicians.	Defendants show no genuine issue of material fact; qualified immunity and proper procedures apply.	No genuine issue; district court properly granted summary judgment.
Whether Kraft was validly admitted to Bellevue Hospital under NY Mental Hygiene Law § 9.39.	Admittance violated statute requirements.	District court record supports proper admission.	Waived issue on appeal; not raised below.
Whether the district court abused its discretion in denying Kraft's reconsideration.	Reconsideration should have altered outcome.	No erroneous law or clearly erroneous factual finding.	No abuse of discretion; reconsideration denied.

Molinari v. Bloomberg, 564 F.3d 587 (2d Cir. 2009) (de novo review of summary judgment standard)
Barfield v. N.Y. City Health & Hosp. Corp., 537 F.3d 132 (2d Cir. 2008) (factors for summary judgment and related standards)
Transaero, Inc. v. La Fuerza Aerea Boliviana, 162 F.3d 724 (2d Cir. 1998) (abuse-of-discretion standard for Rule 60(b) rulings)
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (U.S. 1990) (summary judgment and appellate review standards)
Wal-Mart Stores, Inc. v. Visa U.S.A., Inc., 396 F.3d 96 (2d Cir. 2005) (waiver when new arguments are not pressed below)