Gelb v. Niblack

CourtCourt of Appeals for the Second Circuit
DecidedMay 27, 2025
Docket24-2371
StatusUnpublished

This text of Gelb v. Niblack (Gelb v. Niblack) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gelb v. Niblack, (2d Cir. 2025).

Opinion

24-2371 Gelb v. Niblack

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 27th day of May, two thousand twenty-five.

PRESENT: RICHARD J. SULLIVAN, JOSEPH F. BIANCO, STEVEN J. MENASHI, Circuit Judges. ______________________________________

BERNARD GELB,

Plaintiff-Appellant,

v. No. 24-2371

PRESTON NIBLACK, individually and in his official capacity as Commissioner of the NYC Department of Finance, NEW YORK CITY DEPARTMENT OF FINANCE,

Defendants-Appellees. _______________________________________ For Plaintiff-Appellant: BERNARD GELB, pro se, Rego Park, NY.

For Defendants-Appellees: REBECCA L. VISGAITIS (Ingrid R. Gustafson, on the brief), for Muriel Goode-Trufant, Corporation Counsel of the City of New York, New York, NY.

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Rachel P. Kovner, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the August 13, 2024 judgment of the district

court is AFFIRMED.

Bernard Gelb, proceeding pro se, appeals the district court’s denial of his

motion for default judgment and dismissal of his amended complaint, which

alleged that the New York City Department of Finance and its Commissioner

(collectively, “Defendants”) violated the Due Process Clause and Takings Clause

of the Fifth Amendment, the Equal Protection Clause of the Fourteenth

Amendment, and the New York Freedom of Information Law (“FOIL”). In

essence, Gelb alleged that Defendants’ policy of cancelling tax-refund checks six

months after issuance without providing the recipients notice prior to cancellation

violated the recipients’ constitutional rights. Gelb also alleged that Defendants

violated his constitutional rights and the FOIL by failing to provide him with certain information about the recipients whose refund checks had been cancelled.

On appeal, Gelb only argues that the district court erred by (1) holding that he

lacked standing to sue on behalf of refund recipients and (2) refusing to grant his

motion for default judgment. We assume the parties’ familiarity with the

underlying facts, the procedural history, and issues on appeal.

We review a district court’s dismissal for lack of standing de novo. See Am.

Psychiatric Ass’n v. Anthem Health Plans, Inc., 821 F.3d 352, 357 (2d Cir. 2016). To

survive such a motion, a plaintiff must show by a preponderance of the evidence

that the court has the power to adjudicate the case. See Cortlandt St. Recovery Corp.

v. Hellas Telecomms., S.A.R.L., 790 F.3d 411, 417 (2d Cir. 2015); Branch of Citibank,

N.A. v. De Nevares, 74 F.4th 8, 15 (2d Cir. 2023). The plaintiff therefore must

“clearly allege facts demonstrating [that] each element” of standing has been met.

Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016) (alterations accepted and internal

quotation marks omitted).

While litigants are typically barred “from asserting the rights or legal

interests of others in order to obtain relief from injury to themselves,” Keepers, Inc.

v. City of Milford, 807 F.3d 24, 40 (2d Cir. 2015) (internal quotation marks omitted),

the Supreme Court has “recogniz[ed] that there may be circumstances where it is

3 necessary to grant a third party standing to assert the rights of another,” Kowalski

v. Tesmer, 543 U.S. 125, 129–30 (2004). To do so, a third-party plaintiff must

establish, among other things, “(1) a close relationship to the injured party and (2)

a barrier to the injured party’s ability to assert its own interests.” Keepers, Inc., 807

F.3d at 41 (internal quotation marks omitted).

Gelb argues on appeal that the district court erred by holding that he failed

to establish a close relationship with the refund recipients. He insists that such a

close relationship existed because he, as a potential vendor, would serve as an

effective proponent of the refund recipients’ rights given that they would be his

potential customers. We disagree. Although the Supreme Court has held that

vendors may sue on behalf of their customers under certain circumstances, see, e.g.,

Craig v. Boren, 429 U.S. 190, 195 (1976), it has made clear that there is a difference

between “existing” and “hypothetical” relationships, Kowalski, 543 U.S. at 131.

Ultimately, the Court in Kowalski determined that the plaintiffs did not have third-

party standing to sue on behalf of hypothetical clients, in part because the plaintiffs

did not have “a close relationship with their alleged clients” and, “indeed, . . .

ha[d] no relationship at all.” Id. (internal quotation marks omitted). The Court

also explained that the plaintiffs did not have a close relationship with the

4 potential clients because their case did not “fall[] within th[e] class of cases where

[the Court] ha[s] allowed standing to litigate the rights of third parties when

enforcement of the challenged restriction against the litigant would result indirectly

in the violation of third parties’ rights.” Id. (internal quotation marks omitted).

Like the plaintiffs in Kowalski, Gelb has no relationship whatsoever with the refund

recipients, and he has not alleged that the challenged restriction was enforced

against him, let alone that such enforcement would result indirectly in the

violation of third-party rights.

Gelb attempts to sidestep Kowalski by arguing that the Supreme Court

overruled it in June Medical Services L.L.C. v. Russo, 591 U.S. 299 (2020). But while

it is true that the Court in June Medical Services found that abortion providers had

third-party standing to represent potential patients in challenging a law that

regulated the providers’ own conduct, the Court based that holding on the

longstanding practice of “permit[ing] abortion providers to invoke the rights of

their . . . potential patients in challenges to abortion-related regulations,” which

turned on the fact that “the ‘enforcement of the challenged restriction against the

litigant would result indirectly in the violation of third parties’ rights.’” 591 U.S.

at 138 (quoting Kowalski, 543 U.S. at 130). Far from overruling Kowalski, the Court

5 in June Medical Services reaffirmed Kowalski’s holding that a plaintiff may have

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Haggerty v. Ciarelli & Dempsey
374 F. App'x 92 (Second Circuit, 2010)
Craig v. Boren
429 U.S. 190 (Supreme Court, 1976)
Kowalski v. Tesmer
543 U.S. 125 (Supreme Court, 2004)
Lepelletier v. Federal Deposit Insurance
164 F.3d 37 (D.C. Circuit, 1999)
Keepers, Inc. v. City of Milford
807 F.3d 24 (Second Circuit, 2015)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Gelb v. Niblack, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gelb-v-niblack-ca2-2025.