In Re: New York City Policing During Summer 2020 Demonstrations

CourtCourt of Appeals for the Second Circuit
DecidedMarch 19, 2025
Docket24-695
StatusUnpublished

This text of In Re: New York City Policing During Summer 2020 Demonstrations (In Re: New York City Policing During Summer 2020 Demonstrations) 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
In Re: New York City Policing During Summer 2020 Demonstrations, (2d Cir. 2025).

Opinion

24-695(L) In re: New York City Policing During Summer 2020 Demonstrations

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 19th day of March, two thousand twenty-five.

Present: DEBRA ANN LIVINGSTON, Chief Judge, REENA RAGGI, WILLIAM J. NARDINI, Circuit Judges. _____________________________________

THE PEOPLE OF THE STATE OF NEW YORK, ADAM GRAY, JARRETT PAYNE, KAYLA ROLON, COREY GILZEAN, MICHAEL HERNANDEZ, CHRISTOPHER HUSARY, KEITH CLINGMAN, JONATHAN PECK, JASON DONNELLY, DIANA ZEYNEB ALHINDAWI, JEMELL D. COLE, AMR ALFIKY,

Plaintiffs-Appellees,

v. 24-695 24-1443 24-1439 24-1434

BILL DE BLASIO, CITY OF NEW YORK, DERMOT F. SHEA, TERENCE A. MONAHAN, LARS FRANTZEN, FIERRO, JON BRODIE, PICHARDO, ALTAMIRANO, ROBERT DIXSON, SCOTT HALDEMAN, EDUARD LUCERO, BRITNEY OWENS, HEMME, ANTHONY

1 POLANCO, ERIK RODRIGUEZ, PATRICK GROSS, LUIS E. ORTIZ, N. CANALE, MIGUEL CRUZ, JOSEPH A. TAYLOR, NEW YORK POLICE DEPARTMENT, THEODORE WELLS, JOHN DOES 1-38, JANE DOES 1- 38, SEAN P. ROBINSON, BRIANNA CARLO, NICHOLAS TERRETT, LUIGI TIRRO, ADAM MUNIZ, LEONEL GIRON, KEITH GALLAGHER, GZIM PALAJ, DANIEL SLEVIN, KEITH HOCKADAY, DANIEL GALLAGHER, ROBERT CATTANI, CHRISTOPHER RADZINSKI, STEPHEN SPATARO,

Defendants-Appellees,

POLICE BENEVOLENT ASSOCIATION OF THE CITY OF NEW YORK, INC.,

Intervenor-Defendant- Appellant,

SERGEANTS BENEVOLENT ASSOCIATION,

Intervenor,

v.

JOHN DOES 1-20, JANE DOES 1-20,

Defendants. _____________________________________

For Plaintiffs-Appellees People of the State of PHILIP J. LEVITZ, Senior Assistant Solicitor New York: General of Counsel, (Barbara D. Underwood, Solicitor General, Ester Murdukhayeva, Deputy Solicitor General, on the brief) on behalf of Letitia James, Attorney General of the State of New York.

For Individual Plaintiffs-Appellees: MOLLY K. BIKLEN, (Daniel R. Lambright, Christopher T. Dunn, on the brief), New York Civil Liberties Union Foundation, New York, NY.

Jennvine Wong, Paula Garcia Salazar, The Legal Aid Society, New York, NY.

Corey Stoughton, Selendy Gay PLLC, New York, NY.

2 For Municipal Defendants-Appellees MACKENZIE FILLOW, Assistant Corporation Counsel (Richard Dearing and Devin Slack, on the brief) on behalf of Muriel Goode-Trufant, Acting Corporation Counsel of the City of New York, NY.

For Intervenor-Defendant-Appellant: STEVEN A. ENGEL (Brian A. Kulp, on the brief) Dechert LLP., New York, NY.

Appeal from a decision and order of the United States District Court for the Southern

District of New York (McMahon, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Intervenor-Defendant-Appellant Police Benevolent Association of the City of New York,

Inc. (“PBA”) appeals from a decision and order of the United States District Court for the Southern

District of New York, entered on February 7, 2024, granting plaintiffs-appellees’ motion to dismiss

pursuant to Federal Rule of Civil Procedure 41(a)(2) and approving the terms of a proposed

consent decree in four civil actions consolidated under the caption In re New York City Policing

During Summer 2020 Demonstrations. We assume the parties’ familiarity with the underlying

facts, the procedural history of the case, and the issues on appeal, which we discuss here only as

necessary to explain our decision to AFFIRM.

The consolidated actions were brought by New York State and private plaintiffs

(collectively, “plaintiffs”), naming as defendants the City of New York and its leadership (the

“City”), the New York City Police Department and its leadership (the “NYPD”), and NYPD

officers in their individual and official capacities (collectively, the “Municipal Defendants”).

Plaintiffs’ claims relate to police actions and practices in response to demonstrations that occurred

in the summer of 2020. After engaging in intensive settlement discussions for more than a year,

3 plaintiffs and the Municipal Defendants reached an agreement for the NYPD to alter its practices

for policing protests and demonstrations, and submitted a stipulation of settlement (the

“Settlement”) alongside a motion for voluntary dismissal pursuant to Rule 41(a)(2). The district

court approved the Settlement as a consent decree, over the PBA’s objections. It also granted

plaintiffs’ motion to dismiss. On appeal, the PBA argues that the district court erred by (1) granting

plaintiffs’ Rule 41(a)(2) motion over the objections of a non-settling defendant; (2) approving the

consent decree without considering the impact of the Settlement on officer safety; and (3) failing

to hold an evidentiary hearing prior to ruling. The PBA is wrong on all counts. We address each

of its arguments in turn.

I. Motion to Dismiss Pursuant to Rule 41(a)(2)

Federal Rule of Civil Procedure 41(a)(2) provides that, except under circumstances

inapplicable here, “an action may be dismissed at the plaintiff’s request only by court order, on

terms that the court considers proper.” We review a district court’s decision to grant a Rule

41(a)(2) motion for abuse of discretion. Paysys Int’l, Inc. v. Atos IT Servs. Ltd., 901 F.3d 105, 108

(2d Cir. 2018) (“Rule 41(a)(2) dismissals are at the district court’s discretion and only will be

reviewed for an abuse of that discretion.”).

In determining whether to grant a Rule 41(a)(2) motion for dismissal with prejudice, courts

ask “whether the defendant would suffer some plain legal prejudice from a dismissal . . . , beyond

the prospect of a second lawsuit.” 9 Charles Alan Wright & Arthur R. Miller, Federal Practice

and Procedure § 2364 (4th ed. 2024); see Camilli v. Grimes, 436 F.3d 120, 123 (2d Cir. 2006)

(“[D]ismissal [pursuant to Rule 41(a)(2)] would be improper if the defendant would suffer some

plain legal prejudice other than the mere prospect of a second lawsuit.” (internal quotation marks

4 omitted)). 1 We have previously noted that, “[w]hen the Supreme Court identified ‘plain legal

prejudice’ to a defendant as a circumstance that would defeat [voluntary] dismissal of a plaintiff’s

suit . . . [t]he Court was concerned about the plight of a defendant who is ready to pursue a claim

against the plaintiff in the same action that the plaintiff is seeking to have dismissed.” Camilli,

436 F.3d at 124 (emphasis omitted). Thus, a defendant may suffer “plain legal prejudice” when a

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In Re: New York City Policing During Summer 2020 Demonstrations, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-new-york-city-policing-during-summer-2020-demonstrations-ca2-2025.