Scott v. New York City Department of Correction
445 F. App'x 389
2d Cir.2011Background
- Scott, proceeding pro se, appeals a district court ruling from SDNY.
- District court denied leave to amend the complaint and reopen discovery based on Rule 16(b) good cause standard.
- District court partially granted summary judgment in favor of defendants.
- Court in limine rulings: evidence of harassment by two other individuals excluded under Rule 404(b).
- Jury found in favor of Norman Seabrook and COBA; Scott’s remaining claims were dismissed.
- On appeal, Scott challenges these rulings; the Second Circuit affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the denial of leave to amend and reopen discovery was proper. | Scott argues for relief due to attorney negligence. | Defendants contend no good cause under Rule 16(b) | Affirmed denial. |
| Whether the district court properly granted summary judgment. | Scott asserts triable issues exist. | No genuine issues of material fact; defendants entitled to judgment as a matter of law. | Affirmed summary judgment for defendants. |
| Whether the in limine ruling excluding certain evidence was proper. | Evidence should be admissible to show character and propensity. | Evidence excluded under Rule 404(b) to avoid propensity inference. | Affirmed evidentiary ruling. |
| Whether the jury verdict on harassment claims was supported by sufficient evidence. | Evidence supports Scott’s claims. | Evidence supports defendants; verdict proper. | Affirmed verdict for Seabrook and COBA. |
Key Cases Cited
- Parker v. Columbia Pictures Indus., 204 F.3d 326 (2d Cir. 2000) (Rule 16(b) good-cause standard governs post-deadline amendments; abuse of discretion standard for scheduling orders)
- Link v. Wabash R.R. Co., 370 U.S. 626 (U.S. 1962) (voluntary selection of counsel may affect ability to challenge counsel’s conduct)
- Petrosino v. Bell Atl., 385 F.3d 210 (2d Cir. 2004) (discovery rulings reviewed for abuse of discretion)
- In re DG Acquisition Corp., 151 F.3d 75 (2d Cir. 1998) (trial court broad discretion in pre-trial discovery)
- Borger v. Yamaha Int’l Corp., 625 F.2d 390 (2d Cir. 1980) (preserves challenge to judgment when no post-trial JMOL motion)
- Miller v. Wolpoff & Abramson, L.L.P., 321 F.3d 292 (2d Cir. 2003) (summary judgment standard; de novo review)
- Davis v. State of N.Y., 316 F.3d 93 (2d Cir. 2002) (conclusory allegations not sufficient to defeat summary judgment)