Williams v. King
679 F. App'x 86
| 2d Cir. | 2017Background
- Plaintiff Andrew Williams, a pro se prisoner, sued prison officials alleging violations of his First Amendment free exercise rights and procedural due process, plus retaliation for filing grievances about those issues.
- After the district court dismissed some retaliation claims on summary judgment, a four-day jury trial resulted in a verdict for the defendants on the remaining claims.
- Williams sought to amend to add Superintendent Cunningham for affirming a grievance denial about denial of participation in certain religious holidays (2009); the district court denied leave to amend.
- Williams challenged evidentiary rulings (testimony by Imam Mumbdi) and the district court’s alleged failure to pursue certain complaint allegations his counsel did not press.
- The district court granted summary judgment dismissing Williams’s retaliation claims tied to a disciplinary hearing, reasoning a prior stipulation and withdrawal of related due-process claims showed abandonment.
- The Second Circuit affirmed in part, vacated in part, reinstated the retaliation claims related to the disciplinary hearing, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment properly dismissed retaliation claims arising from a cell search (against King, Katz, Huggler) | Williams contended the cell search was retaliatory following grievances | Defendants argued no personal involvement by King and no causal connection between grievances and the search | Affirmed: district court correctly dismissed these claims for lack of personal involvement and causal connection |
| Whether denial of leave to amend to add Superintendent Cunningham was proper | Williams argued amendment should be allowed to add claim about grievance denial | Defendants opposed as futile or untimely | Affirmed (de novo review noted): even if error, harmless because jury found no constitutional violation on underlying conduct |
| Whether testimony by Imam Mumbdi should have been precluded / grounds for new trial or adding Mumbdi as defendant | Williams argued Mumbdi’s testimony was improper and warranted a new trial or to add him as a defendant | Defendants argued testimony admissible; post-judgment motions untimely | Affirmed: any evidentiary error would be harmless; district court’s postjudgment order denying relief not reviewable on this appeal for lack of an amended notice of appeal |
| Whether summary judgment improperly dismissed retaliation claims tied to the disciplinary hearing (against King and Mead) | Williams argued the stipulation dismissing a due-process claim did not withdraw retaliation claims and that adverse action can support retaliation even if not a due-process violation | Defendants argued the stipulation and plaintiff’s abandonment meant those claims were withdrawn or that there was no adverse action left | Reversed/Vacated: district court erred; retaliation claims reinstated and remanded for further proceedings |
Key Cases Cited
- Garcia v. Hartford Police Dep’t, 706 F.3d 120 (2d Cir. 2013) (summary judgment review standard)
- Doninger v. Niehoff, 642 F.3d 334 (2d Cir. 2011) (summary judgment requires no genuine dispute of material fact)
- Smith v. Hogan, 794 F.3d 249 (2d Cir. 2015) (de novo review where denial to amend is based on legal futility)
- Arlio v. Lively, 474 F.3d 46 (2d Cir. 2007) (abuse-of-discretion standard for evidentiary rulings)
- Pescatore v. Pan Am. World Airways, Inc., 97 F.3d 1 (2d Cir. 1996) (plain-error review in civil cases requires extreme caution)
- LoSacco v. City of Middletown, 71 F.3d 88 (2d Cir. 1995) (issues not raised on appeal may be deemed abandoned)
- Link v. Wabash R.R. Co., 370 U.S. 626 (U.S. 1962) (party bound by actions of counsel)
- Jackson v. Fed. Express, 766 F.3d 189 (2d Cir. 2014) (claims not referenced in counseled filings may be deemed abandoned)
- Davis v. Goord, 320 F.3d 346 (2d Cir. 2003) (elements of a First Amendment retaliation claim in the prison context)
- Dolan v. Connolly, 794 F.3d 290 (2d Cir. 2015) (retaliation claims by prisoners should be approached with skepticism; adverse actions need not be constitutional violations)
- Sorensen v. City of New York, 413 F.3d 292 (2d Cir. 2005) (appellate jurisdiction limits where no proper notice of appeal from postjudgment order)