Blaney v. County of Nassau

CourtDistrict Court, E.D. New York
DecidedMay 7, 2025
Docket2:24-cv-01134
StatusUnknown

This text of Blaney v. County of Nassau (Blaney v. County of Nassau) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blaney v. County of Nassau, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

MARY BLANEY, and FRANCES LOMBARDI, MEMORANDUM & ORDER 24-CV-01134 (HG) (ARL) Plaintiffs,

v.

TOWN OF OYSTER BAY, et al.,

Defendants.

HECTOR GONZALEZ, United States District Judge: Before the Court are two separate motions to dismiss for failure to state a claim: one from Defendant Town of Oyster Bay, and another from Defendants County of Nassau, Carnell Foskey, Denise Vedder, John O’Connor, Beth McKenzie, Patrick O’Connor, and Nassau County Police Department (“County Defendants”). ECF Nos. 39, 40 (Motions to Dismiss). For the reasons set out below, and for the reasons described in the Court’s August 19, 2024, Order, the Court grants both motions and dismisses Plaintiffs’ Amended Complaint. See ECF No. 34 (Aug. 19, 2024, Order); ECF No. 38 (Amended Complaint; “AC”).1

1 Two Defendants, Lisa O’Connor and Christopher Poggiali (the “Non-Appearing Defendants”), have not yet appeared in this action. The Court dismisses the claims against those Defendants for the same reasons it dismisses the claims against the other Defendants. “The district court has the power to dismiss a complaint sua sponte for failure to state a claim . . . so long as the plaintiff is given notice and an opportunity to be heard.” Wachtler v. Cnty. of Herkimer, 35 F.3d 77, 82 (2d Cir. 1994). Here, Plaintiffs were “given notice that the [other] defendants were moving to dismiss,” and Plaintiffs had—and took—multiple opportunities to respond. Id.; see ECF Nos. 41, 42, 44 (Plaintiffs’ Responses). The Court therefore dismisses the claims against all Defendants, including the Non-Appearing Defendants, for the reasons discussed below. BACKGROUND2 On February 14, 2024, Plaintiffs Mary Blaney and Frances Lombardi commenced this fee-paid pro se action pursuant to 42 U.S.C. § 1983 (“Section 1983”).3 ECF No. 1 (Complaint). Defendant Town of Oyster Bay filed a pre-motion letter in anticipation of a motion to dismiss

Plaintiffs’ Complaint, and County Defendants filed a separate letter in anticipation of the same. ECF Nos. 19, 28 (Pre-Motion Letters). On August 19, 2024, the Court issued an Order warning Plaintiffs that Defendants had identified “serious questions about Plaintiffs’ claims that would be sufficient grounds to dismiss the Complaint” in their pre-motion letters, outlined the issues likely to result in the dismissal of Plaintiffs’ Complaint, and directed Plaintiffs to file an amended complaint. ECF No. 34 at 4. Plaintiffs did so on September 23, 2024. See AC. After Plaintiffs filed the AC, Defendant Town of Oyster Bay and County Defendants filed subsequent pre- motion letters in anticipation of motions to dismiss, arguing that the AC merely “restates the wording of numerous allegations,” and still fails to state a claim against Defendants. ECF No. 39 at 1; see ECF No. 40. The Court converted those letters to motions to dismiss “[b]ecause of

the straightforward nature of the grounds for dismissal that are set forth in Defendants’ letters, and because Plaintiffs’ [AC] [did not cure] the deficiencies in their case identified in the Court’s August 19, 2024, Order.” November 15, 2024, Text Order. LEGAL STANDARD A complaint must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible “when the

2 The Court refers to the pages assigned by the Electronic Case Files system (“ECF”). Unless otherwise noted, case law quotations in this Order omit all alterations, internal quotation marks, citations, and footnotes.

3 The Court assumes the parties’ familiarity with the factual allegations, which the Court described in its August 19, 2024, Order. See ECF No. 34. plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Matson v. Bd. of Educ., 631 F.3d 57, 63 (2d Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Although all allegations contained in a complaint are assumed to be true, this tenet is “inapplicable to legal conclusions.” Iqbal,

556 U.S. at 678. A pro se complaint “must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007). The Court’s obligation “to construe a pro se complaint liberally” continues to apply “[e]ven after Twombly” established the plausibility standard for assessing pleadings. Newsome v. Bogan, 795 F. App’x 72, 72 (2d Cir. 2020). Typically, “a pro se complaint should not be dismissed without granting leave to amend at least once” whenever the Court “cannot rule out any possibility, however unlikely it might be, that an amended complaint would succeed in stating a claim.” Elder v. McCarthy, 967 F.3d 113,

132 (2d Cir. 2020). But where “the problem with [a pro se plaintiff’s] causes of action is substantive[,] better pleading will not cure it,” and leave to amend may be properly denied as “futile.” Cuoco v. Moritsugu, 222 F.3d 99, 112 (2d Cir. 2000). In addition to requiring sufficient factual matter to state a plausible claim for relief, pursuant to Rule 8 of the Federal Rules of Civil Procedure, a plaintiff must provide a short, plain statement of claim against the defendant so that it has adequate notice of the claims against it. Iqbal, 556 U.S. at 677–78 (Rule 8 “demands more than an unadorned, the-defendant-unlawfully- harmed-me accusation”). A pleading that only “tenders naked assertions devoid of further factual enhancement” will not suffice. Id. at 678. To satisfy this standard, a complaint must, at a

minimum, “disclose sufficient information to permit the defendant to have a fair understanding of what the plaintiff is complaining about and to know whether there is a legal basis for recovery.” Kittay v. Kornstein, 230 F.3d 531, 541 (2d Cir. 2000). DISCUSSION Plaintiffs purport to bring their claims pursuant to Section 1983. “Section 1983 provides

a civil claim for damages against any person who, acting under color of state law, deprives another of a right, privilege or immunity secured by the Constitution or the laws of the United States.” Rivera v. City of New York, No. 20-cv-9968, 2022 WL 1523165, at *4 (S.D.N.Y. May 13, 2022). However, “Section 1983 is not itself a source of substantive rights, but merely provides a method for vindicating federal rights elsewhere conferred.” Kampfer v. Argotsinger, 856 F. App’x 331, 333 (2d Cir. 2021). For Plaintiffs to bring a claim under Section 1983, they must show that the harm was “committed by a person acting under color of state law,” and that the action “deprived [the plaintiff] of rights, privileges, or immunities secured by the Constitution or laws of the United States.” Cornejo v. Bell, 592 F.3d 121, 127 (2d Cir. 2010). Subject to limited exceptions, Section 1983 does not apply to claims against private individuals

or private organizations. Am. Mfrs. Mut. Ins.

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Matson v. BD. OF EDUC., CITY SCHOOL DIST. OF NY
631 F.3d 57 (Second Circuit, 2011)
Cornejo v. Bell
592 F.3d 121 (Second Circuit, 2010)
Elder v. McCarthy
967 F.3d 113 (Second Circuit, 2020)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)

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Blaney v. County of Nassau, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blaney-v-county-of-nassau-nyed-2025.