Schoolcraft v. City of New York
296 F.R.D. 231
S.D.N.Y.2013Background
- This case concerns City Defendants, Mauriello, and Medical Defendants facing injunction and various motions in a civil rights/claims matter involving NYPD disciplinary proceedings against Adrian Schoolcraft.
- In 2013 the Court issued an injunction staying NYPD administrative proceedings pending resolution of the federal action and potential collateral estoppel issues.
- City Defendants sought to lift the injunction by waiving collateral estoppel, but the Court denied lifting the injunction after evaluating Younger abstention and irreparable harm factors.
- Mauriello moved to amend his answer to add counterclaims (tortious interference and prima facie tort) based on a 2009 plan to frame him, which would delay proceedings; the motion was denied.
- Medical Defendants sought a protective order regarding video deposition of Aldana-Bernier and argued that Plaintiff’s videotaping method violated Rule 30(b) notice and Rule 28 requirements; Plaintiff’s requests for deposition expenses were denied in part.
- Plaintiff’s motion to strike Mauriello’s counterclaims was denied as moot since the amendment was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention requires maintaining the injunction | Schoolcraft argued Younger applies; ongoing NYPD proceeding implicates state interests and requires injunctive relief | City contends no Younger abstention due to lack of strong state interest and timing concerns | Younger abstention not required; injunction can continue pending resolution of the action |
| Whether Mauriello may amend his answer to add counterclaims | Amendment timely; relates back under CPLR tolling rules | Amendment would be prejudicial, unduly delayed, and futile given discovery and timeline | Leave to amend denied due to undue delay and prejudice; counterclaims untimely and would delay resolution |
| Whether the proposed counterclaims relate back under Rule 15 and tolling rules | Relation back should render timely under NY tolling; relates back to original complaint | Relation back not sufficient to save timeliness; tolling analysis uncertain | Related back analysis leads to timely counterclaims under tolling |
| Whether the deposition videotaping and notice requirements were properly handled; and whether sanctions are warranted | Video recording allowed under stipulation and notice | No proper Rule 30(b) notice; attorney-operated recording not compliant; confidentiality concerns | Protective order granted in part; videotaping by counsel denied; deposition expenses denied; other issues reserved |
| Whether deposition-related expenses should be awarded | Should be reimbursed due to improper scheduling by opponents | No sanctions due to proper notice failures and as per rules | Deposition expenses denied |
Key Cases Cited
- Mullins v. City of New York, 554 F.Supp.2d 483 (S.D.N.Y. 2008) (irreparable harm and likelihood of success factors for preliminary injunctions)
- Diamond D Construction Corp. v. McGowan, 282 F.3d 191 (2d Cir. 2002) (Younger's requirements and exceptional relief framework)
- McDonald v. Metro-North Commuter R.R., 565 F.Supp. 37 (S.D.N.Y. 1983) (application of Younger abstention to police/departments proceedings)
- McCune v. Frank, 521 F.2d 1152 (2d Cir. 1975) (context of state proceedings and federal intervention)
- Evans v. Syracuse City Sch. Dist., 704 F.2d 44 (2d Cir. 1983) (considerations on delay and prejudice in denying amendments)