Cagan v. Rittenhouse

CourtDistrict Court, E.D. New York
DecidedMarch 29, 2024
Docket2:22-cv-00260
StatusUnknown

This text of Cagan v. Rittenhouse (Cagan v. Rittenhouse) 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
Cagan v. Rittenhouse, (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------x

TOD S. CAGAN,

Plaintiff, MEMORANDUM & ORDER 22-CV-00260(EK)(LGD)

-against-

NEW YORK CITY POLICE OFFICER GREGORY RITTENHOUSE, et al.,

Defendants.

------------------------------------x

ERIC KOMITEE, United States District Judge: Tod Cagan was arrested and prosecuted in Nassau County for allegedly assaulting Gregory Rittenhouse, an officer of the New York Police Department. Rittenhouse pressed state criminal charges against Cagan, alleging Cagan tricked him into vaping marijuana. Cagan denies that he assaulted anyone. The complaint alleges that his assault prosecution was adjourned in contemplation of dismissal under N.Y. Crim. Proc. Law § 170.55(2). Under that procedure, following a probationary period, Cagan’s charges would be “deemed to have been dismissed.” Cagan now sues various defendants under 42 U.S.C. § 1983, alleging that Rittenhouse’s charges, and his attendant arrest and prosecution, were part of a cover-up to protect Rittenhouse from being fired for a positive drug test. Rittenhouse, his fellow NYPD officer Michael Philbin, and the City of New York have moved to dismiss in part. Except for the “John Doe” defendants allegedly employed by Nassau County, the other defendants have all appeared. Rittenhouse and Philbin both move to dismiss Cagan’s

Section 1983 claims for false arrest and malicious prosecution. The City moves to dismiss all claims against it. For the reasons that follow, the motions are granted. I. Background The following factual background is taken from Cagan’s amended complaint, ECF No. 32, and assumed to be true for purposes of this motion. Cagan lives across the street from defendant Philbin, an NYPD officer, in the Village of Freeport in Nassau County. Am. Compl. ¶ 36. One night in June of 2018, Cagan gave Philbin a ride by boat to the Nautical Mile area of Freeport. Id. ¶ 38. Cagan and Philbin proceeded to separate destinations there. But

hours later, Philbin and his friend, defendant Rittenhouse, asked Cagan for a ride back. Id. ¶ 43. Cagan obliged. Some time after the three men arrived at Cagan’s house, Rittenhouse entered the bathroom. Id. ¶ 45. After Rittenhouse exited the bathroom, Cagan noticed vomit and urine “all over his bathroom.” Id. ¶ 47. After cleaning his bathroom, Cagan met Rittenhouse and Philbin in his kitchen. Id. ¶¶ 47–48. Rittenhouse asked Cagan about a vaporizer pen on Cagan’s kitchen table. Id. ¶ 49. He asked, “what’s in the vape pen?” Id. Cagan responded, “It’s CBD” — cannabidiol, a marijuana extract. Id. CBD’s legality has evolved since June 2018.

Nevertheless, as explained below, it was quite likely, if not certain, that possession of a CBD vaporizer was a crime at that time — under both federal and state law. Following this conversation, Philbin and Rittenhouse left Cagan’s home and contacted Philbin’s friend, a Village of Freeport Police Officer named Michael Geniale, who met Philbin and Rittenhouse outside of Philbin’s home. Id. ¶ 51. They told Geniale that Rittenhouse “was at a bar” in Freeport and had “inhaled a puff of a vape pen that belonged to a stranger.” Id. ¶ 52. After speaking with a sergeant, Geniale instructed Rittenhouse and Philbin to call 911, request an ambulance, and

go to the hospital. Id. ¶ 53.1 Rittenhouse and Philbin then called 911. Id. ¶ 55. Another VFPD Officer arrived, and, per a police report, Rittenhouse and Philbin reiterated that Rittenhouse “was at a bar and inhaled a puff of a Vaporizer pen that belonged to a

1 Cagan does not allege a basis for knowing precisely what was said in this conversation, although he states that his entire complaint is alleged “upon information and belief.” Am. Compl. 1. stranger.” Id. ¶ 56. Rittenhouse went to the hospital and tested positive for THC. Id. ¶ 57. Later that day, Rittenhouse pressed state criminal assault charges against Cagan. See id. ¶ 60. In statements to the Freeport Police Department, Rittenhouse and Philbin both claimed that Rittenhouse was deceived by Cagan, into inhaling

while at Cagan’s home — not a bar. See id. ¶¶ 62–63. They reported that Cagan said the vaporizer contained “just tobacco,” but then subsequently revealed that it contained “medical marijuana.” Id. On June 17, 2018 — the day after Rittenhouse’s positive THC test — Geniale and other VFPD officers arrested Cagan at his home. Id. ¶ 64. He was detained overnight and arraigned the next day, when he was charged with felony assault and released on his own recognizance. Id. ¶¶ 66–67. Some six months later, Cagan accepted an adjournment in contemplation of dismissal (ACD) of his state criminal case.

Id. ¶¶ 30, 77. The complaint alleges that Cagan “is presently seeking to have his ACD disposition vacated and, thereafter, have the charges dismissed.” Id. ¶ 30. II. Legal Standards At the pleading stage, “all well-pleaded, nonconclusory factual allegations in the complaint” are assumed to be true. Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111, 124 (2d Cir. 2010). To survive a motion to dismiss on Rule 12(b)(6) grounds, the complaint must plead sufficient “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 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).2 Courts “are not bound to accept as true a legal conclusion couched as a factual allegation,” and “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). III. Discussion A. Rittenhouse’s and Philbin’s Motions to Dismiss Rittenhouse and Philbin move to dismiss the false arrest and malicious prosecution Section 1983 claims against

them. 1. False Arrest A Section 1983 false arrest claim requires the plaintiff to plead that: (1) the defendant acted under color of

2 Unless otherwise noted, when quoting judicial decisions this order accepts all alterations and omits all citations, footnotes, and internal quotation marks. state law; (2) the defendant “intended to confine him”; (3) the plaintiff was conscious of the confinement; (4) the plaintiff did not consent to the confinement; and (5) the confinement was not otherwise privileged. Posr v. Doherty, 944 F.2d 91, 96–97 (2d Cir. 1991). Only two of these elements are in dispute: first, whether Philbin and Rittenhouse acted under color of

state law; and second, whether that confinement “was privileged, that is, whether the [defendants] had probable cause to arrest” Cagan. Guan v. City of N.Y., 37 F.4th 797, 804, 807 (2d Cir. 2022). “Under ‘color’ of law means under ‘pretense’ of law” and “acts of officers in the ambit of their personal pursuits are plainly excluded.” Pitchell v. Callan, 13 F.3d 545, 547–48 (2d Cir. 1994) (quoting Screws v. United States, 325 U.S. 91, 111 (1945)).

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Cagan v. Rittenhouse, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cagan-v-rittenhouse-nyed-2024.