Parker v. Alexander

CourtCourt of Appeals for the Second Circuit
DecidedMarch 23, 2026
Docket25-487
StatusPublished

This text of Parker v. Alexander (Parker v. Alexander) 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
Parker v. Alexander, (2d Cir. 2026).

Opinion

25-487-cv Parker v. Alexander

United States Court of Appeals for the Second Circuit August Term, 2025

(Argued: December 17, 2025 Decided: March 23, 2026)

Docket No. 25-487-cv _____________________________________

ANGELICA PARKER,

Plaintiff-Appellant,

v.

TAL ALEXANDER, ALON ALEXANDER, OREN ALEXANDER,

Defendants-Appellees. _____________________________________

Before:

JACOBS, CABRANES, and LOHIER, Circuit Judges.

This appeal raises an important question of New York law: Whether two New York State laws, the Child Victims Act (CVA), N.Y. C.P.L.R. § 214-g, and the Adult Survivors Act (ASA), N.Y. C.P.L.R. § 214-j, preempt a New York City law, the Victims of Gender-Motivated Violence Protection Law (VGMVPL), N.Y.C. Admin. Code § 10-1105(a). New York City’s VGMVPL establishes a two-year revival window to permit victims of sexual and gender-based violence to pursue civil claims. New York State’s CVA and ASA establish earlier revival periods to permit victims to sue for similar conduct. The Plaintiff asserted previously time- barred claims under the City’s VGMVPL 2022 Amendments. District courts in this Circuit have come to conflicting resolutions as to whether the VGMVPL window is preempted by the claim-revival provisions in the State’s CVA and ASA. Because no New York court has addressed this question, and because this appeal raises issues of importance to New York, including home rule authority under the New York State Constitution, we defer decision in order to certify the following question to the New York Court of Appeals: Whether the two-year revival window established by New York City’s VGMVPL to permit victims of sexual and gender-based violence to pursue civil claims is preempted by the earlier revival periods set forth in New York State’s CVA and ASA. QUESTION CERTIFIED.

Judge Jacobs concurs in a separate opinion.

MICHAEL J. WILLEMIN (Brooke Payton, on the brief), Wigdor LLP, New York, NY, for Plaintiff-Appellant.

MILTON L. WILLIAMS (Deanna M. Paul, on the brief), Walden Macht Haran & Williams LLP, New York, NY, for Defendant-Appellee Tal Alexander.

LOHIER, Circuit Judge:

This appeal 1 raises an important question of New York law: Whether the

two-year revival window established by New York City’s Victims of Gender-

Motivated Violence Protection Law (VGMVPL or “the city law”), N.Y.C. Admin.

1 This appeal was originally heard in tandem with another appeal, Doe v. Black, 25-564- cv, which raised substantially the same legal question. Because the defendant in Doe v. Black has filed a motion for relief that the district judge presiding over that proceeding lacked authority to grant pending our appeal, we remanded Doe v. Black, 25-564-cv, for further proceedings. See Fed. R. App. P. 12.1; see also Fed. R. Civ. P. 62.1; Fed. R. App. P. 47(b).

2 Code § 10-1105(a), to permit victims of sexual and gender-based violence to

pursue civil claims is preempted by the earlier revival periods in New York

State’s Child Victims Act (CVA), N.Y. C.P.L.R. § 214-g, and Adult Survivors Act

(ASA), id. § 214-j (collectively, “the state laws”). The appeal arises from a lawsuit

in the United States District Court for the Southern District of New York

(Kaplan, J.) brought by a victim of abuse. The Plaintiff asserted claims that

indisputably would have been time-barred but for the New York City Council’s

2022 amendments to the VGMVPL establishing a claim-revival window. The

Defendants argue that the state laws preempt the city law.

Whether the city law must cede to the state laws at issue raises important

issues involving the structure of New York’s form of government, the

relationship between New York State and its municipalities, and home rule

principles reflected in the New York State Constitution. See City of New York v.

Patrolmen’s Benevolent Ass’n of City of N.Y., 89 N.Y.2d 380, 390–91 (1996). Nor can

we ignore the potentially significant implications of this appeal for the statewide

remedial scheme for victims of sexual and gender-based violence in New York.

See Jones v. Cattaraugus-Little Valley Cent. Sch. Dist., 96 F.4th 539, 544 (2d Cir.

2024), certified question accepted, 41 N.Y.3d 969 (2024), and certified question

3 answered, 43 N.Y.3d 337 (2025). Finally, as our concurring colleague notes, we are

advised that a “whole bunch of state court cases are lined up awaiting our

resolution of this question.” Jacobs, J., Concurring Op., post at 3. Because the

appeal turns on issues of substantial policy and legal import to the State (and to

the awaiting lower state courts), we defer decision and certify the following

question to the New York Court of Appeals:

Whether the two-year revival window established by New York City’s Victims of Gender-Motivated Violence Protection Law, N.Y.C. Admin. Code § 10-1105(a), to permit victims of sexual and gender- based violence to pursue civil claims, is preempted by the earlier revival periods set forth in New York State’s Child Victims Act, N.Y. C.P.L.R. § 214-g, and Adult Survivors Act, N.Y. C.P.L.R. § 214-j.

BACKGROUND

I

In June 2024 Angelica Parker sued three brothers—Tal, Alon, and Oren

Alexander—in New York state court under the VGMVPL, alleging that they had

sexually assaulted her in 2012. After the Alexanders successfully removed the

state action against them to federal court based on diversity jurisdiction, they

moved to dismiss Parker’s claims as time-barred, claiming that the ASA and

CVA preempted the VGMVPL’s revival window. The District Court accepted

the defense argument that the ASA and CVA actually conflict with and therefore

4 preempt the VGMVPL’s revival window. It also determined that the scope of the

statutes indicated an intent on the part of the New York State legislature to

occupy the field exclusively on the issue of revival windows for claims of sexual

assault and other forms of gender-based violence. Parker v. Alexander, 779 F.

Supp. 3d 361, 365–69 (S.D.N.Y. 2025). 2

This appeal followed.

DISCUSSION

New York City’s VGMVPL rose from the partial ashes of a federal law to

protect women victimized by violence. As originally enacted, that law, the

Violence Against Women Act of 1994 (VAWA), 42 U.S.C. § 13981, provided

victims of gender-based violence a private civil right of action in federal court

against their assailants. Six years later, however, VAWA’s provision of a private

federal right of action fell prey to United States v.

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Parker v. Alexander, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-alexander-ca2-2026.