Parker v. Alexander

CourtDistrict Court, S.D. New York
DecidedJanuary 22, 2025
Docket1:24-cv-04813
StatusUnknown

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

Bluebook
Parker v. Alexander, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee ee ee ee ee ee ee ee ee ee ee ee HX ANGELICA PARKER, Plaintiff,

-against- 24-cv-4813 (LAK)

TAL ALEXANDER, ALON ALEXANDER, and OREN ALEXANDER Defendants. ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee AX

MEMORANDUM OPINION

Appearances: Michael John Willemin ee Brooke Payton | USDC SDNY Attorneys for Plaintiff | DOCUMENT | ELECTRONICALLY FILED || Isabelle A. Kirshner jpoce:__}, Bil brig in Tre GAR DATE FILED: I CLAYMAN ROSENBERG KIRSHNER & LINDER LLP Lennon a ae Attorneys for Defendants Alon and Oren Alexander Deanna Paul Milton L. Williams, Jr. WALDEN MACHT HARAN, & WILLIAMS LLP Attorneys for Defendant Tal Alexander

Lewis A. KAPLAN, District Judge. Plaintiff Angelica Parker brings this suit under New York City’s Victims of Gender-Motivated Violence Protection Law (“VGMVPL”) against defendants Tal, Alon, and Oren Alexander. The complaint alleges that plaintiff in the fall of 2012 went to Oren’s home, where Oren’s brothers Tal and Alon sexually assaulted her.? Before the Court are motions (1) by defendants Alon and Oren to dismiss and to strike portions of the complaint, and (2) by defendant Tal for judgment on the pleadings dismissing the complaint against him,’ These raise the question whether the revival provision of the City’s VGMVPL is preempted in part by state statutes.

Factual Background' Plaintiff alleges that she developed a brief personal relationship with Oren Alexander in or around 2012.° That fall, Oren allegedly invited plaintiff to the residence where he lived with his brothers Alon and Tal.° Plaintiff alleges that, after she arrived, Alon and Tal raped her while N.Y.C. Admin. Code §§ 10-1101 ef seg. Complaint, Dit 11-1 (“Compl.”) {J 16-28. Dkt 25, The Court assumes familiarity with the underlying facts and the procedural history and thus provides the minimal background necessary to decide the motions, For the purpose of these motions, the Court assumes the truth of plaintiffs allegations and draws all inferences favorable to plaintiff to which the allegations reasonably are susceptible. Compl. { 16. Id. 9] 6, 17.

Oren sat and watched.’ She alleges also that Tal years later attempted to sexually assault her again, but relented after she screamed so that others nearby could hear.*

Discussion Legal Standard To survive a Rule 12(b}(6) motion, a complaint must plead sufficient facts “to state a claim to relief that is plausible on its face.’ “The standard for granting a Rule 12(c) motion for judgment on the pleadings is identical to that for granting a Rule 12(b)(6) motion for failure to state aclaim.”'® In most cases, a claim is plausible on its face if “the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”'! This pleading requirement is satisfied by “a short and plain statement of the claim showing that the pleader is entitled to relief.”'* “[W]hen considering a preemption argument in the context of a motion to dismiss, the factual allegations relevant to preemption must be viewed in the Id. Jf 22-28. Id. 98 32-33. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). 10 Lynch y. City of New York, 952 F.3d 67, 75 (2d Cir. 2020) (cleaned up) (quoting Patel v. Contemporary Classics, 259 F.3d 123, 126 (2d Cir. 2001)). 11 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 556). 12 Fed, R. Civ. P, 8(a)(2).

light most favorable to the plaintiff.”

2. Statute of Limitations and Revival Provisions The statute of limitations for a claim under the VGMVPL ordinarily is seven years.4 The VGMVPL limitations period for conduct in the fall of 2012 therefore expired in fall 2019. However, in January 2022, the New York City Council amended the VGMYVPL by creating a two- year window for the revival of otherwise time-barred claims under the law (“VGMVPL Revival Amendment” or “Amendment”). That window opened on March 1, 2023, and closes on March 1, 2025.'° Plaintiff contends that this suit — filed on June 18, 2024 — is timely based on the Amendment. Defendants counter that the Amendment is preempted by New York State’s Adult Survivors Act,'° which created a one-year window for the revival of otherwise time-barred civil claims arising out of certain sexual offenses committed against adult victims. That window opened on November 24, 2022, and closed exactly one year later in November 2023'? — more than six months before plaintiff brought this action.

13 Galper y. JP Morgan Chase Bank, N.A., 802 F.3d 437, 444 (2d Cir. 2015). 14 N.Y.C. Admin. Code §§ 10-1105(a). Ifa potential plaintiff person is unable to bring suit for certain listed reasons at the time the cause of action accrues, then “the time within which the action must be commenced shall be extended to nine years after the inability to commence the action ceases.” Jd, Plaintiff not alleged that she was unable to bring suit at the time the cause of action accrued. 15 id. 16 N.Y. CPLR§ 214-7. 17 id.; see also Carroll vy. Trump, 650 F. Supp. 3d 213, 218 (S.D.N.Y. 2023).

The Court addressed this issue in Bellino v. Tallarico."* As here, the plaintiff in Bellino brought a VGMVPL claim outside the ordinary statute of limitations and relied on the VGMVPL Revival Amendment.” The Court concluded that the VGMVPL Revival Amendment in relevant part is preempted by the State’s Child Victims Act (“CVA”Y* and the Adult Survivors Act (“ASA”).”) As no opposition was filed to the defendant’s motion to dismiss in Be/lino, however, the Court did not have the benefit of full briefing in that case. It therefore considers the issue here de novo.

A, Preemption Standard The VGMVPL Revival Amendment is a local New York City enactment. The predicate of defendants’ position is that the ASA and the CVA are New York State statutes which, in relevant part, preempt the claim revival provision of the Amendment. The New York State Constitution’s home rule provision authorizes municipalities to adopt local laws in certain fields so long as they are “not inconsistent” with the Constitution or general state laws.” “The doctrine of preemption acts as a significant restriction on the home rule powers of municipalities. Local laws may be inconsistent with and preempted by state law either

18 No. 24-CV-0712 (LAK), 2024 WL 1344075 (S8.D.N_Y. Feb. 21, 2024). 19 id. at *1, 20 N.Y. CPLR § 214-¢. 2024 WL 1344075 at *1. 22 N.Y, Const., art. IX, § 2(c}(10).

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Parker v. Alexander, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-alexander-nysd-2025.