Cuatetl v. City of New York

2025 NY Slip Op 31166(U)
CourtNew York Supreme Court, New York County
DecidedApril 8, 2025
DocketIndex No. 160109/2021
StatusUnpublished

This text of 2025 NY Slip Op 31166(U) (Cuatetl v. City of New York) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cuatetl v. City of New York, 2025 NY Slip Op 31166(U) (N.Y. Super. Ct. 2025).

Opinion

Cuatetl v City of New York 2025 NY Slip Op 31166(U) April 8, 2025 Supreme Court, New York County Docket Number: Index No. 160109/2021 Judge: Hasa A. Kingo Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 160109/2021 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 04/08/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. HASA A. KINGO PART 5M Justice ---------------------------------------------------------------------------------X INDEX NO. 160109/2021 TOMAS CUATETL, MOTION SEQ. NO. 003 004 Plaintiff,

-v- DECISION + ORDER ON THE CITY OF NEW YORK, DENNIS MCLAUGHLIN, IDRIS MOTION OLAYOKUN, JOHN DOES

Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66 were read on this motion for SUMMARY JUDGMENT .

The following e-filed documents, listed by NYSCEF document number (Motion 004) 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77 were read on this motion for DISMISSAL .

The City of New York (“the City”) moves pursuant to CPLR §§ 3211(a)(7) and 3212 for an order dismissing Plaintiff Tomas Cuatetl’s (“Plaintiff”) federal and state causes of action for failure to state a claim. In particular, the City seeks dismissal of: 1) Plaintiff’s claims for negligent hiring, retention, supervision, and respondeat superior as a matter of law; and 2) Plaintiff’s negligent and intentional infliction of emotional distress claims, and general negligence and prima facie tort claims as a matter of law. Concurrently, Plaintiff has filed an application for an order pursuant to CPLR § 3212 granting summary judgment on his claims for assault and battery against the City under the theory of respondeat superior.

BACKGROUND AND ARGUMENTS

Plaintiff initiated this action on November 7, 2021, asserting multiple causes of action against the City of New York and various correction officers for, among other things, assault and battery, negligence, excessive force, and constitutional violations. On August 15, 2023, Plaintiff moved to amend his complaint to include Correction Officers Dennis McLaughlin and Idris Olayokun as defendants and to supplement his claims. The Hon. Judy H. Kim granted leave to amend pursuant to the relation back doctrine. The City subsequently served an amended answer on or about August 8, 2024; however, the amended answer names only the City, and the newly designated officers have not appeared on the record.

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Central to this dispute is the incident on August 19, 2020, at the Manhattan Detention Complex (“MDC”), where Plaintiff alleges that after being transferred to MDC, he was subjected to a bifurcated series of assaults: first, an assault involving the use of chemical agents during a chaotic struggle, and second, a separate instance of forced fingerprinting despite his clear refusal. Plaintiff asserts that the excessive force applied, particularly in the fingerprinting episode, was neither reasonable nor necessary, in violation of established Department of Corrections (“DOC”) policies. In support of his motion for summary judgment on his assault and battery claim, Plaintiff has offered deposition testimony, video footage of the incident, detailed medical records documenting his injuries, and relevant DOC use-of-force guidelines.

In response, the City contends that Plaintiff’s allegations are conclusory, that genuine issues of material fact exist (particularly as to whether the force was applied as part of a continuum of events in response to Plaintiff’s aggressive conduct), and that Plaintiff has failed to satisfy the heavy burden required to preclude a trial. The City also argues that, even if considered separately, the claims for negligent hiring, retention, supervision, and for negligent/intentional infliction of emotional distress and general negligence are not sustainable under the controlling legal standards.

DISCUSSION

On a motion to dismiss brought under CPLR § 3211 (a)(7), the court must “accept the facts as alleged in the complaint as true, accord the plaintiff the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory” (Leon v Martinez, 84 NY2d 83, 87-88 [1994] [citations omitted]). Ambiguous allegations must be resolved in the plaintiff’s favor (see JF Capital Advisors, LLC v Lightstone Group, LLC, 25 NY3d 759, 764 [2015]). “The motion must be denied if from the pleadings’ four corners factual allegations are discerned which taken together manifest any cause of action cognizable at law” (511 West 232nd Owners Corp. v Jennifer Realty Co., 98 NY2d 144, 152 [2002] [internal citations omitted]). “Whether a plaintiff can ultimately establish its allegations is not part of the calculus in determining a motion to dismiss” (Cortlandt Street Recovery Corp. v Bonderman, 31 NY3d 30, 38 [2018]), but a pleading consisting of “bare legal conclusions” is insufficient (Leder v Spiegel, 31 AD3d 266, 267 [1st Dept 2006], aff’d 9 NY3d 836 [2007], cert denied 552 US 1257 [2008]) and “the court is not required to accept factual allegations that are plainly contradicted by the documentary evidence or legal conclusions that are unsupportable based upon the undisputed facts” (Robinson v Robinson, 303 AD2d 234, 235 [1st Dept 2003]).

A motion for summary judgment “shall be granted if, upon all the papers and proofs submitted, the cause of action or defense shall be established sufficiently to warrant the Court as a matter of law in directing judgment in favor of any party” (CPLR § 3212[b]). “The proponent of a motion for summary judgment must demonstrate that there are no material issues of fact in dispute, and that it is entitled to judgment as a matter of law” (Dallas-Stephenson v Waisman, 39 AD3d 303, 306 [1st Dept 2007]). The movant’s burden is “heavy,” and “on a motion for summary judgment, facts must be viewed in the light most favorable to the non-moving party” (William J. Jenack Estate Appraisers & Auctioneers, Inc. v Rabizadeh, 22 NY3d 470, 475 [2013] [internal quotation marks and citation omitted]). Upon a proffer of evidence establishing a prima facie case by the movant, the party opposing a motion for summary judgment bears the burden of producing evidentiary proof in admissible form sufficient to require a trial of material questions of fact

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(Zuckerman v City of New York, 49 NY2d 557, 562 [1980]). “A motion for summary judgment should not be granted where the facts are in dispute, where conflicting inferences may be drawn from the evidence, or where there are issues of credibility” (Ruiz v Griffin, 71 AD3d 1112, 1115 [2d Dept 2010] [internal quotation marks and citation omitted]).

In determining the proper disposition of motions for summary judgment and for dismissal, this court must view the evidence in the light most favorable to the non-moving party and is obligated to conclude that summary judgment is only appropriate when no material issues of fact remain (CPLR § 3212[b]; Dallas-Stephenson, 39 AD3d at 306, supra).

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Bluebook (online)
2025 NY Slip Op 31166(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/cuatetl-v-city-of-new-york-nysupctnewyork-2025.