Rapaport v. Iyer

CourtCourt of Appeals for the Second Circuit
DecidedJune 15, 2026
Docket25-841
StatusUnpublished

This text of Rapaport v. Iyer (Rapaport v. Iyer) 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
Rapaport v. Iyer, (2d Cir. 2026).

Opinion

25-841-cv Rapaport v. Iyer 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 TO 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 15th day of June, two thousand twenty-six.

PRESENT: JON O. NEWMAN, RICHARD C. WESLEY, MYRNA PÉREZ, Circuit Judges. _____________________________________

GIDEON RAPAPORT, Plaintiff-Appellant,

v. No. 25-841

AJAY SRINIVASAN IYER, ZACHARY GEORGE GARRETT, RICHARD ALLEN EPSTEIN, Defendants-Appellees,

JOHN DOE #1, A REDDIT.COM USER, JOHN DOE #2, A TOP-LAW-SCHOOLS.COM USER, JOHN DOE #3, A CURRENT OR FORMER NYU LAW STUDENT, INDIVIDUALLY, MITCHELL KEVALLA PALLAKI, Defendants. _____________________________________ FOR PLAINTIFF-APPELLANT: GIDEON RAPAPORT, pro se, Jersey City, NJ.

FOR DEFENDANTS-APPELLEES AJAY BRIAN J. FIELD (Justin A. Miller, on the SRINIVASAN IYER AND ZACHARY brief), Schaerr Jaffe LLP, Washington, DC. GEORGE GARRETT:

FOR DEFENDANT-APPELLEE JEREMY CHASE, Davis Wright Tremaine RICHARD ALLEN EPSTEIN: LLP, New York, NY.

Appeal from the March 31, 2025, order of the United States District Court for the

Southern District of New York (Clarke, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the District Court is AFFIRMED.

Plaintiff-Appellant Gideon Rapaport, proceeding pro se, appeals the order of the

District Court dismissing his counseled amended complaint bringing various state law

claims against Defendants-Appellees Iyer, Garrett, and Epstein (together, “Defendants”).

We assume the parties’ familiarity with the underlying facts, the procedural history of

the case, and the issues on appeal.

“We review de novo a district court’s dismissal of a complaint pursuant to Rule

12(b)(6), construing the complaint liberally, accepting all factual allegations in the

complaint as true, and drawing all reasonable inferences in the plaintiff’s favor.” Mazzei

v. Money Store, 62 F.4th 88, 92 (2d Cir. 2023) (quoting Green v. Dep’t of Educ. of N.Y.C., 16

F.4th 1070, 1076 (2d Cir. 2021)). We review de novo a district court’s “legal

interpretation and application of a statute of limitations.” Sutton v. Tapscott, 120 F. 4th

1115, 1119 (2d Cir. 2024) (quoting Ray v. Ray, 22 F.4th 69, 72 (2d Cir. 2011)). We may 2 affirm “on any ground that finds support in the record, even if it was not the ground

upon which the trial court relied.” Wells Fargo Advisors, LLC v. Sappington, 884 F.3d 392,

396 n.2 (2d Cir. 2018) (quoting Headley v. Tilghman, 53 F.3d 472, 476 (2d Cir. 1995)).

I. Timeliness

The District Court dismissed certain claims and allegations of defamation in the

operative First Amended Complaint (“FAC”) as time-barred, which Rapaport now

challenges. A federal court exercising diversity jurisdiction applies the statute of

limitations that the forum state would apply. See Stuart v. American Cyanamid Co., 158

F.3d 622, 626–27 (2d Cir. 1998). Here, New York’s statute of limitations applies because

Rapaport brought this action in a federal court sitting in New York, and the alleged events

and injuries occurred in New York. See id. Under New York law, a defamation claim

must be asserted within one year of the date of the first publication of the allegedly

defamatory statement. See Van Buskirk v. N.Y. Times Co., 325 F.3d 87, 89 (2d Cir. 2003)

(citing N.Y. C.P.L.R. 215(3)). The District Court explained that “[e]ven though Plaintiff

arguably filed the original complaint within the limitations period, the Amended

Complaint requires its own timeliness analysis because it adds new claims and parties.”

Rapaport v. Iyer, No. 23-CV-6709, 2025 WL 966275, at *6 (S.D.N.Y. Mar. 31, 2025). And

whether the addition of those new claims and parties in the FAC may be deemed timely

3 depends on whether they “relate back” to the original complaint. See id.; Hogan v.

Fischer, 738 F.3d 509, 517–20 (2d Cir. 2013).

The District Court determined that Rapaport’s original complaint “focused only

on the ‘anonymous internet posts.’” Rapaport, 2025 WL 966275, at *8. It thus found that

the FAC’s new allegations regarding Defendants’ communications with the Federalist

Society were untimely and limited its consideration of the FAC to allegations and claims

involving the internet postings themselves. See id. at *8–9. We discern no error in this

analysis and agree that the new allegations are time-barred. 1

II. Claims on the Merits

Having dismissed the allegations beyond the internet posts as untimely, the

District Court dismissed the remainder of Rapaport’s claims as insufficiently pled.

Rapaport, 2025 WL 966275, at *9–15. The District Court did not err in doing so. For

substantially the reasons explained by the District Court, we affirm its dismissal of

Rapaport’s remaining state-law claims.

Most substantively, Rapaport’s defamation claims are insufficiently pled. In

reaching the same conclusion, the District Court properly considered screenshots of the

1 Because only Iyer and Garrett raised the timeliness issue in their motion to dismiss, the District Court considered the timeliness of the allegations against Epstein sua sponte. The District Court did not err in doing so. See Walters v. Indus. & Com. Bank of China, Ltd., 651 F.3d 280, 293 (2d Cir. 2011). 4 internet posts attached to the FAC as Exhibit 3. The screenshots are of internet posts in

online discussion threads, and they show multiple anonymous participants in

conversation with each other. The FAC does not identify which statements are alleged

to have been posted by which of the Defendants. This is fatal to Rapaport’s defamation

claims because when it comes to defamation, “the complaint [must] afford defendant

sufficient notice of the communications complained of to enable him to defend himself.”

See Tannerite Sports, LLC v. NBCUniversal News Grp., 864 F.3d 236, 251 & n.10 (2d Cir. 2017)

(alteration in original) (quoting Kelly v. Schmidberger, 806 F.2d 44, 46 (2d Cir. 1986)).

Indeed, “[v]agueness as to the complained-of conduct is particularly inappropriate when

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Related

Kelly v. Schmidberger
806 F.2d 44 (Second Circuit, 1986)
Amidax Trading Group v. S.W.I.F.T. Scrl
671 F.3d 140 (Second Circuit, 2011)
Walters v. INDUSTRIAL AND COMMERCIAL BANK OF CHINA
651 F.3d 280 (Second Circuit, 2011)
Hogan v. Fischer
738 F.3d 509 (Second Circuit, 2013)
Green v. Dep't of Educ.
16 F.4th 1070 (Second Circuit, 2021)
Ray v. Ray
22 F.4th 69 (Second Circuit, 2021)
Tannerite Sports, LLC v. NBCUniversal News Group
864 F.3d 236 (Second Circuit, 2017)
Mazzei v. the Money Store
62 F.4th 88 (Second Circuit, 2023)
Sutton v. Tapscott
120 F.4th 1115 (Second Circuit, 2024)

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Rapaport v. Iyer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rapaport-v-iyer-ca2-2026.