Santiago v. City of New York
697 F. App'x 36
| 2d Cir. | 2017Background
- Plaintiff Jesus Santiago sued the City of New York and unnamed NYPD officers alleging assault and related civil-rights and state-law claims.
- Complaint used "John Does" for officer defendants and contained primarily conclusory allegations about the alleged assault.
- The City moved for judgment on the pleadings under Fed. R. Civ. P. 12(c); the Magistrate Judge recommended dismissal.
- The District Court adopted the R&R, entered judgment for the City, and denied Santiago leave to amend under Fed. R. Civ. P. 15.
- Santiago appealed, arguing (1) the complaint met pleading requirements despite being conclusory, (2) denial of leave to substitute named officers was improper, and (3) New York notice-of-claim requirements should not bar his state-law claims in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleadings | Santiago contended conclusory allegations sufficed to state plausible claims. | City argued complaint lacked factual allegations to plausibly state claims. | Court affirmed dismissal: conclusory allegations are insufficient (Twombly/Iqbal). |
| Leave to amend to name officers | Santiago sought leave to substitute John Does with officer names. | City opposed; District Court argued proposed amendment added no new facts. | Denial of leave to amend affirmed for abuse-of-discretion standard; proposed amendment was still conclusory. |
| Application of state notice-of-claim statute | Santiago argued filing in federal court avoids NY notice-of-claim requirement. | City argued state notice-of-claim statutes apply to state-law claims in federal court. | Court held New York notice-of-claim requirement applies in federal court; claims subject to dismissal. |
| Standard of review for denial of amendment | Implied: Santiago contended denial was improper. | City: District Court applied abuse-of-discretion review and found no grounds to allow amendment. | Court reviewed for abuse of discretion and found no abuse. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaints must plead enough facts to be facially plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations are not entitled to be assumed true)
- Hayden v. Paterson, 594 F.3d 150 (2d Cir. 2010) (standard of review de novo for Rule 12(c) motions)
- Pyskaty v. Wide World of Cars, LLC, 856 F.3d 216 (2d Cir. 2017) (abuse-of-discretion standard for denial of leave to amend)
- F5 Capital v. Pappas, 856 F.3d 61 (2d Cir. 2017) (leave to amend may be denied if plaintiff cannot plausibly cure defects)
- Hardy v. New York City Health & Hosp. Corp., 164 F.3d 789 (2d Cir. 1999) (state notice-of-claim statutes apply to state-law claims in federal court)