Monk v. United States

CourtDistrict Court, D. Connecticut
DecidedFebruary 11, 2025
Docket3:22-cv-01503
StatusUnknown

This text of Monk v. United States (Monk v. United States) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Monk v. United States, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

CONLEY F. MONK JR., et al., Plaintiffs, No. 3:22-cv-1503 (SRU)

v.

UNITED STATES, Defendant.

ORDER DENYING MOTION FOR CERTIFICATION TO PURSUE AN INTERLOCUTORY APPEAL

The government has moved for certification to pursue an interlocutory appeal of my order denying its motion to dismiss. For the following reasons, I deny the government’s motion for certification for an interlocutory appeal, doc. no. 96. I. Standard of Review “Litigants are generally required to wait for a final judgment to appeal.” Century Pacific, Inc. v. Hilton Hotels Corp., 574 F. Supp. 2d 369, 370 (S.D.N.Y. 2008) (citing Klinghoffer v. S.N.C. Achille Lauro, 921 F.2d 21, 25 (2d Cir. 1990)). “[O]nly exceptional circumstances will justify a departure from the basic policy of postponing appellate review until after the entry of a final judgment.” Klinghoffer, 921 F.2d at 25 (cleaned up). “The party that seeks certification under section 1292(b) bears the heavy burden of demonstrating that the case is an exceptional one in which immediate appeal is warranted.” In re Aggrenox Antitrust Litig., 2018 WL 834228, at *1 (D. Conn. Feb. 12, 2018) (quoting White v. Nix, 43 F.3d 374, 376 (8th Cir. 1994)) (cleaned up). Pursuant to 28 U.S.C. § 1292(b), a district judge may certify an order for interlocutory appeal when the judge is “of the opinion that such order [1] involves a controlling question of law [2] as to which there is substantial ground for difference of opinion and [3] that an immediate appeal from the order may materially advance the ultimate termination of the litigation[.]” 28 U.S.C. § 1292(b). A substantial ground for difference of opinion requires a showing that “(1) there is conflicting authority on an issue or (2) the case is particularly difficult

and of first impression within this Circuit.” James v. Venture Home Solar, LLC, 2024 WL 446085, at *11 (D. Conn. Feb. 6, 2024) (quoting United States ex rel. Drake v. NSI, Inc., 736 F. Supp. 2d 489, 503 (D. Conn. 2010)). The three criteria of section 1292(b) “are conjunctive, not disjunctive.” Williston v. Eggleston, 410 F. Supp. 2d 274, 276 (S.D.N.Y. 2006) (quoting Ahrenholz v. Bd. of Trs. of Univ. of Illinois, 219 F.3d 674, 676 (7th Cir. 2000)). Courts may deny interlocutory review if any one of the above three criteria is not satisfied. See id. at 278 (denying motion for leave to appeal because there was “no substantial ground for a difference of opinion”); see also In re Liddle & Robinson, LLP, 2020 WL 4194542, at *4 (S.D.N.Y. July 21, 2020) (denying motion for leave to appeal after considering only “the last of the § 1292(b) factors”).

Indeed, “even when a party has demonstrated that the criteria of 28 U.S.C. § 1292(b) are met,” district courts have “unfettered discretion to deny certification.” In re World Trade Ctr. Disaster Site Litig., 469 F. Supp. 2d 134, 144 (S.D.N.Y. 2007) (quoting Gulino v. Board of Education, 234 F. Supp. 2d 324, 325 (S.D.N.Y. 2002)). Whether to certify a question of law for interlocutory review “is entirely a matter of discretion for the District Court.” Tarpon Bay Partners LLC v. Zerez Holdings Corp., 2019 WL 10984250, at *1 (D. Conn. Oct. 29, 2019) (quoting In re The City of New York, 607 F.3d 923, 933 (2d Cir. 2010)). If the district court certifies an interlocutory appeal, “[t]he relevant Court of Appeals may then, ‘in its discretion, permit an appeal to be taken from such order.’” Balintulo v. Daimler AG, 727 F.3d 174, 186 (2d Cir. 2013) (quoting 28 U.S.C. § 1292(b)) (footnote omitted).

II. Background I assume the parties’ familiarity with the plaintiffs’ factual allegations.1 The immediately relevant procedural history is as follows. On March 29, 2024, I denied the government’s motion to dismiss in a written order. Doc. No. 83. On June 4, 2024, the government moved for leave to appeal that order. The government seeks certification to appeal the following issues:2 1. Whether 38 U.S.C. § 511(a) bars judicial review of Plaintiffs’ claims where Plaintiffs disclaim challenging individual benefits decisions by the United States Department of Veterans Affairs (“VA”) and instead allege that the VA has engaged in “systemic” discrimination in its grant and denial of benefits, and 2. Whether there is a private-party analog in state tort law sufficient to support Plaintiffs’ claims brought under the Federal Tort Claims Act (“FTCA”), which seek damages predicated upon the VA’s alleged negligence in administering a racially discriminatory benefits system. Mem. of Law, Doc. No. 96-1 at 6. III. Discussion The government meets some—but not all—of section 1292(b)’s criteria for interlocutory review. As set forth below, my order denying the government’s motion to dismiss (a) “involves a controlling question of law,” and (b) “an immediate appeal from the order may materially advance the ultimate termination of the litigation[.]” 28 U.S.C. § 1292(b). But the government fails to fully satisfy section 1292(b)’s criteria for interlocutory review because there is not (c)

1 I discuss those factual allegations in greater detail in the order denying the government’s motion to dismiss. Doc. No. 83; Monk v. United States, 2024 WL 1344712 (D. Conn. Mar. 24, 2024). 2 “[S]ection 1292(b) authorizes certification of orders for interlocutory appeal, not certification of questions[,]” but “it is helpful if the district judge frames the controlling question(s) that the judge believes is presented by the order being certified[.]” Isra Fruit Ltd. v. Agrexco Agr. Exp. Co., 804 F.2d 24, 25 (2d Cir. 1986). “substantial ground for difference of opinion” on either issue for which it seeks appellate review. Id.

A. Materially Advance the Ultimate Termination of the Litigation An interlocutory appeal’s likelihood of ending the litigation depends, in part, on whether the appeal could dispose of all issues. In re Facebook, Inc., IPO Sec. & Derivative Litig., 986 F. Supp. 2d 524, 532 (S.D.N.Y. 2014). If the Second Circuit were to reverse my order on either the section 511(a) issue or the FTCA issue, this Court would lose subject matter jurisdiction over the entire case. Certification thus could materially advance the terminate of the litigation.

B. Controlling Questions of Law “Although technically the question of whether there is a controlling issue of law is distinct from the question of whether certification would materially advance the ultimate termination of the litigation, in practice the two questions are closely connected.” Id. at 536 (quoting S.E.C. v.

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Monk v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/monk-v-united-states-ctd-2025.