Heuser v. City of Glen Cove

Court of Appeals for the Second Circuit·Decided June 22, 2026·No. 25-541·Unpublished

Opinion

25-541-cv Heuser v. City of Glen Cove

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 22nd day of June, two thousand twenty-six.

PRESENT: PIERRE N. LEVAL, MICHAEL H. PARK, EUNICE C. LEE, Circuit Judges. _____________________________________

Kristina S. Heuser,

Plaintiff-Appellant,

v. 25-541

City of Glen Cove, Richard J. McCord,

Defendants-Appellees. _____________________________________

FOR PLAINTIFF-APPELLANT: Kristina S. Heuser, pro se, Naples, FL. FOR DEFENDANT-APPELLEE CITY OF GLEN COVE: Leo Dorfman, Sokoloff Stern LLP, Carle Place, NY.

FOR DEFENDANT-APPELLEE RICHARD J. McCORD: Kenneth L. Gartner, Lynn Gartner Dunne Frigenti & Renke, LLP, Melville, NY.

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

District of New York (Joan M. Azrack, J.; Steven I. Locke, M.J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the district court is AFFIRMED.

Plaintiff Kristina Heuser, an attorney proceeding pro se, appeals from the district

court’s dismissal of her complaint. Heuser sued her former employer, the City of Glen

Cove, New York, and Richard McCord, a judge on the Glen Cove City Court, under 42

U.S.C. § 1983, Title VII, and New York state law. Plaintiff alleged that Judge McCord

created a hostile work environment and that she was constructively discharged from

her job as a city lawyer based on her sex. Defendants moved to dismiss, and a

magistrate judge recommended granting the motion, reasoning that Heuser failed

timely to serve Defendants, Judge McCord was immune from suit, and Heuser

otherwise failed to state a claim. The district court adopted the recommendation.

Heuser v. City of Glen Cove, No. 21-cv-2018 (JMA) (SIL), 2023 WL 11852409 (E.D.N.Y.

2 June 30, 2023), R&R adopted, 2025 WL 373636 (E.D.N.Y. Feb. 3, 2025). We assume the

parties’ familiarity with the facts, the procedural history, and the issues on appeal.

I. Rule 12(b)(5) Dismissal

“We review a dismissal under Rule 12(b)(5) based on insufficient service of

process for abuse of discretion.” Dickerson v. Napolitano, 604 F.3d 732, 740 (2d Cir.

2010). “[W]hen a defendant moves to dismiss under Rule 12(b)(5), the plaintiff bears

the burden of proving adequate service.” Id. at 752 (alteration in original) (quotation

marks omitted). Under Federal Rule of Civil Procedure 4(m), a plaintiff has 90 days to

serve the defendants after the complaint is filed. Dismissals for failure to effectuate

timely service under Rule 4(m) generally will not be reversed “unless the appellant can

advance some colorable excuse for neglect.” Meilleur v. Strong, 682 F.3d 56, 61 (2d Cir.

2012) (quotation marks omitted).

A. City of Glen Cove

The district court did not abuse its discretion by dismissing the claims against

the City of Glen Cove for insufficient service of process. It is undisputed that Heuser

did not serve Defendants for nine months after filing the complaint—six months after

the time for service expired. Nor did Heuser demonstrate good cause for the delay in

service. In her response to an order to show cause, she claimed that she was unaware

that summonses had been issued because of mail-forwarding issues and her lack of

3 PACER access. But she admitted that she did not prioritize this case nor take any

affirmative steps to monitor the docket until nine months after she filed her complaint,

so she cannot establish excusable neglect for her failure to comply with Rule 4(m). Cf.,

e.g., Alexander v. Saul, 5 F.4th 139, 149-50 & n.7 (2d Cir. 2021) (concluding that a litigant

who failed to take reasonable steps to stay apprised of proceedings in her suit and thus

lacked notice of the district court’s decision was not excused from failing timely to file

an appeal).

Heuser argues that the district court abused its discretion because it did not grant

her an extension of time by which to serve Defendants. Before dismissing a complaint

sua sponte, a district court should provide “notice to the plaintiff” and “provid[e] an

opportunity for her to show good cause for the failure to effect timely service.”

Meilleur, 682 F.3d at 61. An extension of time may be granted, even absent good cause.

Id. However, if the district court chooses to dismiss the complaint, reversal is only

warranted under Rule 4(m) if the “the appellant can advance some colorable excuse for

neglect.” Id. (quotation marks omitted). As discussed above, Heuser did not show

excusable neglect in this case. The district court was thus not obligated to provide an

extension of time to effectuate service.

4 B. Judge McCord

The district court also did not abuse its discretion by dismissing the claims

against Judge McCord for insufficient service of process. Although McCord did not

explicitly invoke Rule 12(b)(5) as a ground for dismissal, McCord argued in his motion

to dismiss that Heuser did not timely serve him. Further, McCord explicitly adopted

Glen Cove’s arguments in his reply brief. Heuser argues that the district court should

not have considered this ground for dismissal because new arguments may not be

asserted in reply briefs. While this is generally the rule, the district court nevertheless

had discretion to consider the argument. See Ruggiero v. Warner-Lambert Co., 424 F.3d

249, 252 (2d Cir. 2005). Heuser has not demonstrated that the district court abused its

discretion by considering the argument here. McCord raised the argument by

specifically referring to the belated service of the complaint in his opening brief, and

Heuser cannot claim that she was prejudiced given that Glen Cove asserted the same

argument and she had an opportunity to respond to it.

Accordingly, the district court did not abuse its discretion by dismissing

Heuser’s complaint under Rule 12(b)(5).

II. Leave To Amend

The district court did not err by denying leave to amend the complaint. Denials

of leave to amend based on futility are reviewed de novo. Hutchison v. Deutsche Bank

5 Secs. Inc., 647 F.3d 479, 490 (2d Cir. 2011). “A pro se complaint should not be dismissed

without the [c]ourt granting leave to amend at least once when a liberal reading of the

complaint gives any indication that a valid claim might be stated.” Chavis v. Chappius,

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Heuser v. City of Glen Cove, (2d Cir. 2026).

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Related

Dickerson Ex Rel. Davison v. Napolitano
604 F.3d 732 (Second Circuit, 2010)
Chavis v. Chappius
618 F.3d 162 (Second Circuit, 2010)
Meilleur v. Strong
682 F.3d 56 (Second Circuit, 2012)
Hutchison v. Deutsche Bank Securities Inc.
647 F.3d 479 (Second Circuit, 2011)
Alexander v. Saul, Comm'r of Soc. SEC.
5 F.4th 139 (Second Circuit, 2021)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)