Owens v. The County of Monroe

CourtDistrict Court, W.D. New York
DecidedJuly 10, 2025
Docket6:21-cv-06445
StatusUnknown

This text of Owens v. The County of Monroe (Owens v. The County of Monroe) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Owens v. The County of Monroe, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK _______________________________________

PHILLIP H. OWENS, DECISION AND ORDER Plaintiff, 6:21-CV-6445 FPG CDH v.

THE COUNTY OF MONROE,

Defendant. _______________________________________

INTRODUCTION Plaintiff Phillip H. Owens (“Plaintiff”) asserts a claim against defendant the County of Monroe (“Defendant”) pursuant to 42 U.S.C. § 1983 and Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978). (Dkt. 1). Plaintiff specifically alleges that Defendant “maintained a practice and custom not to reprimand or discipline assistant district attorneys in connection with Brady [v. Maryland, 373 U.S. 83 (1963)] violations and presentation of false or misleading argument, evidence and testimony at trial.” (Dkt. 1 at ¶ 208). Currently pending before the Court is Plaintiff’s motion to unseal the contents of the Monroe County District Attorney’s Office’s (“MCDAO”) files and grand jury materials related to eight New York state cases. (Dkt. 38; see Dkt. 38-1 at 9-10). Defendant opposes Plaintiff’s motion. (See Dkt. 39; Dkt. 52). For the reasons that follow, Plaintiff’s motion is granted in part and denied in part. BACKGROUND I. Factual Background The following facts are taken from Plaintiff’s complaint (Dkt. 1), and have been

“accepted as true” by Defendant for purposes of the instant motion (Dkt. 13 at 1 n.1). On May 31, 2012, Plaintiff’s estranged wife Tara Owens reported to police that while she waited at an intersection in Rochester, New York, Plaintiff fired a gun at her and their three-year-old son from a convenience store. (Dkt. 1 at ¶¶ 17-24; Dkt. 13 at 1-2). Surveillance video, however, failed to show the shooting and contradicted the prosecution’s narrative of the case. (Dkt. 1 at ¶¶ 28-30; Dkt. 13 at 2). Additionally, Ms. Owens recanted her report to the police. (Dkt. 1 at ¶ 41; Dkt. 13 at 2). Ultimately,

Plaintiff was convicted of attempted assault in the first degree, two counts of criminal possession of a weapon in the second degree, and criminal possession of a weapon in the third degree. (Dkt. 1 at ¶ 98; Dkt. 13 at 3). After the trial, Plaintiff’s motion to set aside the verdict was denied. (Dkt. 1 at ¶¶ 106; Dkt. 13 at 3). Subsequently, the New York Supreme Court, Appellate Division reversed Plaintiff’s conviction and remanded the case for a new trial. (Dkt. 1 at ¶ 114; Dkt. 13

at 4). At Plaintiff’s second trial, Ms. Owens refused to testify, asserting her Fifth Amendment right against self-incrimination. (Dkt. 1 at ¶¶ 124-28; Dkt. 13 at 4). Having lost the testimony of this key witness, the MCDAO conveyed it could not proceed, and the state trial court issued a trial order of dismissal on June 13, 2018, leading to Plaintiff’s release from jail. (Dkt. 1 at ¶ 129; Dkt. 13 at 4). II. Procedural Background This matter has been referred to the undersigned for all non-dispositive pretrial proceedings. (See Dkt. 15; Dkt. 40).

Plaintiff commenced this action on June 13, 2021. (Dkt. 1). District Judge Frank P. Geraci, Jr., granted in part Defendant’s motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), dismissing Plaintiff’s claims that Defendant had a de facto policy of (1) refusing to disclose Brady material and presenting false and misleading evidence and testimony at trial, and (2) of training and “directing trial prosecutors to not take notes when interviewing prosecution witnesses, or being deliberately indifferent to such practice, so as to deprive defendants of exculpatory

evidence.” (Dkt. 13 at 6-7). Judge Geraci concluded that Plaintiff sufficiently pled a Monell claim based on a failure to discipline, because he plausibly alleged that “Defendant was on notice of misconduct and failed to investigate and discipline the misconduct . . . [and] it [was] reasonable to infer that a failure to discipline prosecutors in connection with prosecutorial misconduct, including the failure to disclose Brady information, would cause constitutional violations.” (Dkt. 13 at 10-11).

On September 19, 2023, Magistrate Judge Marian W. Payson, to whom the matter was then referred, entered a Stipulated Protective Order. (Dkt. 28). The Stipulated Protective Order provides for the designation of documents as “Confidential” and “Highly Confidential,” and provides relevant protections for appropriately designated documents. (Id.). On November 22, 2024, Plaintiff filed the instant motion to “unseal the complete contents of the District Attorney’s file[s] in” the cases of People v. Fisher, 18 N.Y.3d 964 (2012), People v. Flowers, 151 A.D.3d 1843 (4th Dep’t 2017), People v.

Gibson, 134 A.D.3d 1512 (4th Dep’t 2015), People v. Jones, 134 A.D.3d 1588 (4th Dep’t 2015), People v. Griffin, 125 A.D.3d 1509 (4th Dep’t 2015), People v. Presha, 83 A.D.3d 1406 (4th Dep’t 2011), People v. Valentin, 1 A.D.3d 982 (4th Dep’t 2003), and People v. Fields, Indictment No. 2009-0864 (Feb. 17, 2010) (collectively, the “Cases”). (Dkt. 38). On December 23, 2024, Defendant filed its opposition. (Dkt. 39). Plaintiff filed a reply on January 13, 2025. (Dkt. 41). The Court held oral argument on February

11, 2025, at which time Plaintiff’s counsel advised that Plaintiff was also seeking to unseal grand jury materials related to the Cases. (See Dkt. 44). At the request of Defendant, the Court ordered supplemental briefing on this issue. Plaintiff filed his supplemental brief on March 22, 2025 (Dkt. 49), and Defendant filed its response on April 4, 2025 (Dkt. 52). Plaintiff did not file a reply. DISCUSSION

I. Request to Unseal Criminal Files A. Legal Standard New York Criminal Procedure Law (“CPL”) § 160.50 provides that “[u]pon the termination of a criminal action or proceeding against a person in favor of such person . . . the record of such action or proceeding shall be sealed.” N.Y. CPL § 160.50(1). “The primary purpose of the sealing of records pursuant to § 160.50 is to ensure confidentiality and to protect . . . individual[s] from the potential public stigma associated with a criminal prosecution.” Lehman v. Kornblau, 206 F.R.D. 345, 347 (E.D.N.Y. 2001). Relatedly, New York Civil Rights Law (“CVR”) §50-b provides that

“the identity of any victim of a sex offense . . . shall be confidential” and “[n]o . . . public officer or employee shall disclose any portion of any police report, court file, or other document, which tends to identify such a victim,” subject to delineated exceptions. N.Y. CVR § 50-b(1). “[W]hen a plaintiff sues in federal court to vindicate federal civil rights, New York state law does not govern discoverability and confidentiality[.]” Howard v. City of Rochester, 758 F. Supp. 3d 109, 121 (W.D.N.Y. 2024) (quotation omitted); see also

Crosby v. City of N.Y., 269 F.R.D. 267, 274 (E.D.N.Y. 2010) (“[I]n cases presenting federal questions, such as here, discoverability, privileges, and confidentiality are governed by federal law, not state law.”). Nevertheless, “[i]n the interest of comity, [federal] courts should attempt to recognize state privileges where this can be accomplished at no substantial cost to federal substantive and procedural policy.” Manzi v. DiCarlo, 982 F. Supp. 125, 131 (E.D.N.Y. 1997) (quotation omitted); see also

Coleman v. Cnty. of Suffolk, 174 F. Supp. 3d 747, 757 (E.D.N.Y. 2016), aff’d, 685 F. App’x 69 (2d Cir. 2017). “[T]he policies underlying state evidentiary privileges must . . .

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

Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Douglas Oil Co. of Cal. v. Petrol Stops Northwest
441 U.S. 211 (Supreme Court, 1979)
Manzi v. DiCarlo
982 F. Supp. 125 (E.D. New York, 1997)
Ruther v. Boyle
879 F. Supp. 247 (E.D. New York, 1995)
People v. Fisher
967 N.E.2d 676 (New York Court of Appeals, 2012)
Coleman v. County of Suffolk
685 F. App'x 69 (Second Circuit, 2017)
People v. Flowers
2017 NY Slip Op 4990 (Appellate Division of the Supreme Court of New York, 2017)
People v. Valentin
1 A.D.2d 982 (Appellate Division of the Supreme Court of New York, 2003)
People v. Presha
83 A.D.3d 1406 (Appellate Division of the Supreme Court of New York, 2011)
United States v. Silver
103 F. Supp. 3d 370 (S.D. New York, 2015)
Coleman v. County of Suffolk
174 F. Supp. 3d 747 (E.D. New York, 2016)
Anilao v. Spota
918 F. Supp. 2d 157 (E.D. New York, 2013)
Lehman v. Kornblau
206 F.R.D. 345 (E.D. New York, 2001)
Crosby v. City of New York
269 F.R.D. 267 (S.D. New York, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Owens v. The County of Monroe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/owens-v-the-county-of-monroe-nywd-2025.