Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC

CourtDistrict Court, E.D. New York
DecidedAugust 26, 2024
Docket1:21-cv-01192
StatusUnknown

This text of Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC (Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC) 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
Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC, (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK FAIR HOUSING JUSTICE CENTER, INC., Plaintiff, MEMORANDUM & ORDER -against- 21-CV-1192 (NGG) (JRC) 203 JAY ST. ASSOCIATES, LLC., AMTRUST REALTY CORP., and WOODS BAGOT ARCHITECTS, P.C., Defendants, WOODS BAGOT ARCHITECTS, P.C., Defendant/Third-Party Plaintiff, -against- JFG ARCHITECTS, Third-Party Defendant. AMTRUST REALTY CORP. and 203 JAY ST., Defendants/Third-Party Plaintiffs, -against- BRAVO BUILDERS, LLC., Third-Party Defendant.

NICHOLAS G. GARAUFIS, United States District Judge. Pending before the court are Magistrate Judge James R. Cho’s Report and Recommendation (“R&R”) on Defendant/Third- □ Party Plaintiff Woods Bagot Architects, P.C.’s (“Woods Bagot”) motion for leave to amend its Third-Party Complaint, and Woods Bagot’s Objections to that R&R. (See Not. of Mot. to Amend (Dkt. 118); R&R dated June 14, 2024 (Dkt. 135) (“R&R”); Objections to R&R (Dkt. 138).) For the reasons stated below, the R&R is ADOPTED in full.

I. BACKGROUND As discussed in detail in the court’s prior Memorandum & Order, the court assumes familiarity with the background of this case brought against the owners, developers, and architects of a resi- dential apartment building known as “The Amberly” located in Kings County, New York. This action concerns The Amberly’s ac- cessibility for people with disabilities who use wheelchairs and is filed pursuant to the Fair Housing Act (“FHA”) and related fed- eral and state civil rights laws. (See Mem. & Order dated September 6, 2023 (“M&O”) (Dkt. 116) at 1-3; see also R&R at 3-4.) II. LEGAL STANDARD A district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made” by a magistrate judge in an R&R, 28 U.S.C. § 636(b)(1)(C). Where a party timely and specifically objects, the court conducts a de novo review of the contested portions of the R&R, Fischer v. Forrest, 286 F. Supp. 3d 590, 601 (S.D.N.Y. 2018). “However, when a party makes only conclusory or general objections, or simply reiterates his original arguments, the court reviews the report and recommendation strictly for clear error.” Piligian v. Icahn Sch. of Med. at Mount Sinai, 490 F. Supp. 3d 707, 715 (S.D.N.Y. 2020).! Ii. DISCUSSION Plaintiff raises three objections to the R&R. (See generally Objec- tions to R&R.) The court addresses each objection below. Plaintiff first objects on the basis that the Magistrate Judge has committed “fundamental error” in applying New York’s contribu- tion statute, C.P.L.R. § 1401 by “analyzing the viability of Woods

1 When quoting cases, unless otherwise noted, all citations and internal quotation marks are omitted, and all alterations are adopted.

Bagot’s contribution claim” outside of the “FHA context.” (Objec- tions to R&R at 3-4.) This objection is without merit. While itis —, true that Judge Cho did not cite to cases concerning FHA viola- tions, this court did so in its initial Memorandum & Order, which already established that “claims for partial indemnification or contribution that are proportionate to fault are allowed under the FHA.” (M&O at 6-8, 20.) This court further concluded that the Indemnification Clause found in the Architectural Services Agreement between 203 Jay St. Associates, LLC and Woods Ba- got, “does not pose an obstacle to the intended purpose and effect of the FHA” given that it required Woods Bagot to indemnify Owner Defendants for losses in connection with the performance of services furnished by Woods Bagot, and that such losses would be reduced proportionally to reflect the contribution of any act or omission by Woods Bagot. (Id. at 7-8.) These findings set the context and contours of the motion to amend as well as Judge Cho’s R&R. Nevertheless, Woods Bagot argues that in failing to consider cases based on alleged violations of the FHA, Judge Cho did not undergo a sufficient analysis of Woods Bagot’s contribution and partial common law indemnification claims. (Objections to R&R at 3, 7.) While the court would conclude this is a general objec- tion that needs no further analysis, a de novo review of Woods Bagot’s proposed Amended Third-Party Complaint based on its other objections discussed infra, requires the same result as rec- ommended by Judge Cho. Woods Bagot also objects to Judge Cho’s recommendation deny- ing Woods Bagot’s motion to add a contribution claim, arguing that he did so relying on the undersigned’s prior rulings based on Wood Bagot’s original Third-Party Complaint rather than its pro- posed Amended Third-Party Complaint. Ud. at 5.) This argument is disingenuous and inaccurate.

Specifically, Judge Cho explains: As Judge Garaufis recognized, New York’s contribution statute does not cover “purely economic loss resulting from a breach of contract,” but requires “some form of tort liability.” 9/6/23 M&O at 20-21. Finding that Woods Bagot’s contribution claim was “grounded in contract rather than tort,” Judge Garaufis dismissed the claim. Id. at 21-22 (‘Woods Bagot has failed to allege any form of tort liability against JFG.”). Judge Garaufis held that “[a] plaintiff cannot circumvent [the tort re- quirement] by asserting a negligence claim grounded in a duty created by contract.” Id. at 21. Those rulings are the law of the case, See Arizona v. California, 460 U.S. 605, 618 (1983) (“[Wjhen a court decides upon a rule of law, that decision should continue to govern the same issues in subsequent stages in the same case.”). (R&R at 7.) In the very next paragraph, Judge Cho reviews the proposed Amended Third-Party Complaint to find that Woods Bagot has not corrected the deficiencies identified by this court, but rather “adds a few conclusory allegations that continue to assert that JFG owed a duty of care to Woods Bagot arising out of the pur- ported contract between Woods Bagot and JFG, and that JFG breached that duty.” Ud.) (emphasis in original). Judge Cho fur- ther explains that Woods Bagot’s motion to amend focuses largely on how the undersigned erred in concluding that Woods Bagot failed to allege a basis for tort liability against JFG as re- quired to raise a contribution claim. (Id.) The R&R adds that a motion to amend is not the appropriate vehicle to argue for re- consideration of the undersigned’s ruling on issues of law. (Id. at 8.)

It is inaccurate to suggest that Judge Cho erred in reiterating this court’s prior rulings when Woods Bagot improperly sought to re- litigate those issues. (See Mem. in Support of Mot. to Amend (Dkt. 118-7) at 4-6 (arguing that while the court observed that New York’s contribution statute requires some form of tort liabil- ity, “liability under the Fair Housing Act sounds in tort”).) In any event, a de novo review of case law and the proposed Amended Third-Party Complaint make clear that (1) this court’s previous ruling that Woods Bagot cannot circumvent the tort re- quirement by asserting a negligence claim grounded in contract still stands; (2) such ruling stands in light of cases in the FHA context; and (3) the proposed Amended Third-Party Complaint fails to allege the requisite tort separate from a contractual ben- efit. Starting with the court’s ruling that contribution under CPLR § 1401 requires some form of tort liability to invoke the statute, Woods Bagot assumes that because liability under the FHA sounds in tort, its contribution claim must be permitted on that basis. Ud. at 4-6.) Not so, In Clover Communities Beavercreek, LLC vy. Mussachio Architects P.C., 676 F. Supp. 3d 82, 92-93 (N.D.N.Y.

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Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fair-housing-justice-center-inc-v-203-jay-st-associates-llc-nyed-2024.