Sarkar v. City of New York

CourtCourt of Appeals for the Second Circuit
DecidedJune 30, 2025
Docket24-1219
StatusUnpublished

This text of Sarkar v. City of New York (Sarkar v. City of New York) 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
Sarkar v. City of New York, (2d Cir. 2025).

Opinion

24-1219 Sarkar v. City of New York

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 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 30th day of June, two thousand twenty-five.

PRESENT: GERARD E. LYNCH, RICHARD J. SULLIVAN, STEVEN J. MENASHI, Circuit Judges. ______________________________________

JAY SARKAR,

Plaintiff-Appellant,

v. No. 24-1219

CITY OF NEW YORK, THE SPECIAL COMMISSIONER OF INVESTIGATION FOR THE NEW YORK CITY SCHOOL DISTRICT, NEW YORK CITY DEPARTMENT OF EDUCATION, RICHARD A. CARRANZA, Chancellor of New York City Department of Education, RICHARD CONDON, Special Commissioner of Investigation, ANTOINETTE BELLO, DOE, BARBARA HANSON, DOE, KIM NOHAVICKA, DOE, LAURENCE HENRY, SCI Investigator, DAVID NEGRON, SCI Investigator,

Defendants-Appellees. * _______________________________________

For Plaintiff-Appellant: Jay Sarkar, pro se, Corona, NY.

For Defendants-Appellees: Deborah A. Brenner, Jonathan Schoepp-Wong, for Muriel Goode- Trufant, Corporation Counsel of the City of New York, New York, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Mary Kay Vyskocil, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the March 28, 2024 judgment of the district

court is AFFIRMED.

Jay Sarkar, proceeding pro se, appeals from the district court’s dismissal of

his complaint, which asserted numerous state and federal causes of action against

the City of New York, the New York City Department of Education, and others

(collectively, the “City”), related to his termination in April 2006 as an independent

* The Clerk of Court is respectfully directed to amend the official case caption as set forth above.

2 contractor for the City and the publication in December 2006 of a report by the

Special Commissioner of Investigation (the “SCI”) regarding Sarkar’s conduct.

As relevant here, the district court concluded that Sarkar’s claims for defamation,

fraud, and conspiracy to interfere with his civil rights in violation of 42 U.S.C.

§ 1985 were time-barred and that the doctrines of equitable tolling and equitable

estoppel did not otherwise salvage his claims. We assume the parties’ familiarity

with the underlying facts, procedural history, and issues on appeal.

We review the district court’s application of a statute of limitations de novo.

See Horror Inc. v. Miller, 15 F.4th 232, 241 (2d Cir. 2021). A district court may

dismiss a cause of action as untimely “when a defendant raises . . . lack of

timeliness[] as an affirmative defense and it is clear from the face of the complaint,

and matters of which the court may take judicial notice, that the plaintiff’s claims

are barred as a matter of law.” Sewell v. Bernardin, 795 F.3d 337, 339 (2d Cir. 2015)

(internal quotation marks omitted). When a plaintiff argues that he is entitled to

equitable tolling and the district court determines that such tolling is

inappropriate, “we review the legal premises for that conclusion de novo, the

factual bases for clear error, and the ultimate decision for abuse of discretion.”

Doe v. United States, 76 F.4th 64, 70 (2d Cir. 2023). Because Sarkar has been pro se

3 throughout, we “liberally construe [his] pleadings and briefs . . . , reading such

submissions to raise the strongest arguments they suggest.” McLeod v. Jewish

Guild for the Blind, 864 F.3d 154, 156 (2d Cir. 2017) (internal quotation marks

omitted).

Sarkar first contends that his defamation claim is timely because the City

republished the 2006 SCI report multiple times, including as late as 2019. But

“New York adheres to a single publication rule in determining when the statute of

limitations begins to run on a defamation claim.” Van Buskirk v. N.Y. Times Co.,

325 F.3d 87, 89 (2d Cir. 2003) (citing Gregoire v. G.P. Putnam’s Sons, 298 N.Y. 119,

125 (1948)). Under this rule, “a defamation claim accrues at publication,” which

is “‘the earliest date on which the work was placed on sale or became generally

available to the public.’” Id. at 89 (quoting Tomasino v. William Morrow & Co., 571

N.Y.S.2d 571, 572 (2d Dep’t 1991)); see also Firth v. State, 98 N.Y.2d 365, 370 (2002)

(applying the single publication rule to internet publications). And while it is

true that New York courts have recognized an exception to this rule for certain

republications, that exception applies only where “the subsequent publication is

intended to and actually reaches a new audience, the second publication is made

on an occasion distinct from the initial one, the republished statement has been

4 modified in form or in content, and the defendant has control over the decision to

republish.” Martin v. Daily News L.P., 990 N.Y.S.2d 473, 483 (1st Dep’t 2014)

(internal quotation marks omitted).

Applying New York’s single publication rule to the facts alleged in Sarkar’s

complaint, the district court concluded that Sarkar’s defamation claim accrued in

December 2006 when the City made the SCI report available to the public via its

website. Consequently, Sarkar needed to file his defamation claim by December

2007. See N.Y. C.P.L.R. § 215(3). Sarkar attempts to sidestep that limitation by

arguing that the SCI report was subsequently reposted on various websites. But

these websites were all hosted by the SCI or its parent agency, and the content of

the report never changed. Because the subsequent postings did not target new

audiences and the content of the report did not change, the republication exception

does not apply here. See Martin, 990 N.Y.S.2d at 483.

Sarkar also argues that his fraud claim did not accrue until 2017 because the

City fraudulently concealed the basis for this claim, which did not become

apparent until the City responded to his request under New York’s Freedom of

Information Law (“FOIL”) in November 2017. But the law is clear that tort claims

brought in New York against a municipality and its officers and employees, such

5 as the defendants here, must be filed within one year and ninety days after the

event on which the claim was based. See N.Y. Gen. Mun. Law § 50-i(1); N.Y.

Educ. Law § 3813(2). Thus, even assuming that Sarkar is correct that his fraud

claim did not accrue until November 2017, he still would have been required to

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Related

Ross v. Louise Wise Services, Inc.
868 N.E.2d 189 (New York Court of Appeals, 2007)
Firth v. State of NY
775 N.E.2d 463 (New York Court of Appeals, 2002)
Martin v. Daily News L.P.
121 A.D.3d 90 (Appellate Division of the Supreme Court of New York, 2014)
Jang Ho Choi v. Beautri Realty Corp.
135 A.D.3d 451 (Appellate Division of the Supreme Court of New York, 2016)
Gregoire v. G. P. Putnam's Sons
81 N.E.2d 45 (New York Court of Appeals, 1948)
McLeod v. the Jewish Guild for the Blind
864 F.3d 154 (Second Circuit, 2017)
Horror Inc. v. Miller
15 F.4th 232 (Second Circuit, 2021)
Green v. Dep't of Educ.
16 F.4th 1070 (Second Circuit, 2021)
Doe v. Holy See
17 A.D.3d 793 (Appellate Division of the Supreme Court of New York, 2005)
McIvor v. Di Benedetto
121 A.D.2d 519 (Appellate Division of the Supreme Court of New York, 1986)
Tomasino v. Morrow & Co.
174 A.D.2d 734 (Appellate Division of the Supreme Court of New York, 1991)
Greene v. WCI Holdings Corp.
136 F.3d 313 (Second Circuit, 1998)
Sewell v. Bernardin
795 F.3d 337 (Second Circuit, 2015)
Gonzalez v. Hasty
802 F.3d 212 (Second Circuit, 2015)
Doe v. United States
76 F.4th 64 (Second Circuit, 2023)

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