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Tillman v. Sitek
1:24-cv-00239
W.D.N.Y.
Apr 11, 2025
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Background

  • Plaintiff Garrien Tillman brought a civil rights suit under 42 U.S.C. § 1983 against Niagara Falls police officers following a September 22, 2022, encounter.
  • Plaintiff alleged constitutional violations during his interaction with four named officers: Sitek, General, Mazur, and Grzewkowski.
  • Defendants moved to dismiss the complaint for failure to state a claim.
  • In response, Plaintiff sought permission to amend his complaint to add additional defendants and clarify allegations.
  • The Magistrate Judge recommended denying the motion to dismiss and allowing the amended complaint as to the original and some newly proposed defendants, but not all.
  • Both parties objected to parts of the Magistrate Judge's recommendations, triggering de novo review by the District Court.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the motion to dismiss should be denied Complaint alleges sufficient facts for relief Complaint is insufficient; should be dismissed Denied; complaint stands
Whether Plaintiff should be allowed to amend complaint Amendment clarifies claims/adds necessary parties Amendment is untimely/impermissible as to some parties Granted in part; denied as to Restaino, Fordy, Ligammari
Dismissal of claims against Defendant Mazur Sufficient allegations against Mazur No claim against Mazur Denied; claims remain
Dismissal of certain claims against Defendants General and Grzewkowski Allegations relate to constitutional violations Claims based on prior occurrence or lack adequate facts Denied; claims remain

Key Cases Cited

  • Thomas v. Arn, 474 U.S. 140 (1985) (clarifies a district court's discretion to review or not review unobjected portions of a magistrate judge's recommendation)
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Case Details

Case Name: Tillman v. Sitek
Court Name: District Court, W.D. New York
Date Published: Apr 11, 2025
Docket Number: 1:24-cv-00239
Court Abbreviation: W.D.N.Y.