Schiebel v. Schoharie Central School District

CourtDistrict Court, N.D. New York
DecidedJune 20, 2025
Docket1:22-cv-01109
StatusUnknown

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

Bluebook
Schiebel v. Schoharie Central School District, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

KEITH SCHIEBEL,

Plaintiff,

-against- 1:22-CV-1109 (LEK/DJS)

SCHOHARIE CENTRAL SCHOOL DISTRICT, et al.,

Defendants.

MEMORANDUM-DECISION AND ORDER

I. INTRODUCTION On October 26, 2022, Plaintiff Keith Schiebel filed a complaint against Defendants Schoharie Central School District, Kristen DuGuay, and David Blanchard, alleging gender bias in violation of Title IX and various state torts. Dkt. No. 1 (“Complaint”). Defendants filed a motion to dismiss, and on June 30, 2023, the Court granted the motion in its entirety. Dkt. No. 16 (“June Order”). The Court dismissed Plaintiff’s Title IX claim on the merits and declined to exercise supplemental jurisdiction over Plaintiff’s state law claims. Id. Plaintiff appealed. Dkt. No. 18. On November 26, 2024, the Second Circuit reversed this Court’s judgment insofar as it dismissed Plaintiff’s Title IX claim, and vacated this Court’s judgment insofar as it dismissed Plaintiff’s state tort claims. Dkt. No. 22. The Second Circuit then remanded the action for further proceedings. Id. Now before the Court is Defendants’ motion to dismiss Plaintiff’s state tort claims. Dkt. No. 28. Defendants filed a memorandum of law in support of their motion. Dkt. No. 28-5 (“Motion”). Plaintiff filed a response, Dkt. No. 31 (“Response”), and Defendants replied, Dkt. No. 32. For the reasons that follow, Defendants’ Motion is granted in part and denied in part. II. BACKGROUND The Court assumes familiarity with the factual background of this case as detailed in the June Order. See June Ord. at 1–5. III. LEGAL STANDARD

To survive a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a “complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A court must accept as true the factual allegations contained in a complaint and draw all inferences in favor of a plaintiff. See Allaire Corp. v. Okumus, 433 F.3d 248, 249–50 (2d Cir. 2006). A complaint may be dismissed pursuant to Rule 12(b)(6) only where it appears that there are not “enough facts to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. Plausibility requires “enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of [the alleged misconduct].” Id. at 556.

The plausibility standard “asks for more than a sheer possibility that a defendant has acted unlawfully.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). The Supreme Court has stated that “the pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. (citing Twombly, 550 U.S. at 555). “[W]here the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct,” the pleader has not demonstrated that she is entitled to relief and the action is subject to dismissal. Id. at 679. IV. DISCUSSION Defendants move to dismiss Plaintiff’s claims of (1) tortious interference with contract, (2) negligent infliction of emotional distress, and (3) reckless and wanton misconduct. See Mot. at 4–7. First, they argue that all three state tort claims are time-barred. Id. at 4–5. Then, they

argue that the tortious interference claim and the reckless and wanton misconduct claim fail on their merits. Id. at 5–7. At the outset, the Court notes that “[i]f a court has original jurisdiction, it may exercise supplemental jurisdiction over ‘all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy.’” June Ord. at 14 (quoting 28 U.S.C. § 1367(a)). The Court elects to exercise its supplemental jurisdiction here. A. Plaintiff’s tort claims are not time-barred. Defendants argue that Plaintiff’s tort claims are time-barred. Mot. at 4–5. The Court disagrees. “[W]here tort claims are asserted against a school district, board of education, or ‘any teacher or member of the supervisory administrative staff or employee,’ the applicable

limitations period is ‘one year and ninety days after the happening of the event upon which the claim is based.” Carlson v. Geneva City Sch. Dist., 679 F. Supp. 2d 355, 370 (W.D.N.Y. 2010) (quoting N.Y. Educ. Law § 3813(2); N.Y. Gen. Mun. Law § 50-i(1)); cf. Bey v. Westbury Union Free Sch. Dist., No. 21-CV-2048, 2022 WL 900615, at *5 (E.D.N.Y. Mar. 28, 2022) (noting that N.Y. Educ. Law § 3813(2-b) sets a one-year limitations period for non-tort claims). Here, Plaintiff brings tort claims against Defendants, so the appropriate limitations period is one year and ninety days. See Carlson, 679 F. Supp. 2d at 370. Viewed in the light most favorable to Plaintiff, the latest act of allegedly tortious conduct took place on August 30, 2021. Compl. ¶ 165; see Mot. at 4. The Complaint in this action was filed on October 26, 2022, less than one-year and ninety-days later. See Dkt. No. 1. Accordingly, the Court finds that Plaintiff’s tort claims are not time-barred.1 B. Plaintiff’s tortious interference claim is dismissed. In the Complaint, Plaintiff alleges that “Defendants purposely and wrongfully disrupted

the contractual relationship that existed” between Plaintiff and the New York State Maple Producers Association (“MPA”). Compl. ¶ 184. Defendants argue that this claim must be dismissed because “Plaintiff does not allege that there was a breach of his contract by MPA,” and in the absence of a breach, Plaintiff fails to state a claim. Mot. at 5. Under New York law, a tortious interference with a contract claim requires “[1] the existence of a valid contract between the plaintiff and a third party, [2] defendant’s knowledge of that contract, [3] defendant’s intentional procurement of the third-party’s breach of the contract without justification, [4] actual breach of the contract, and [5] damages resulting therefrom.” Rich v. Fox News Network, LLC, 939 F.3d 112, 126–27 (2d Cir. 2019) (quoting Lama Holding Co. v. Smith Barney Inc., 88 N.Y.2d 413, 424 (N.Y. 1996)). “Failing to allege breach of contract

is fatal to a tortious interference claim.” Synca Direct, Inc. v. Scil Animal Care Co., No. 15-CV- 794, 2015 WL 5970938, at *3 (N.D.N.Y. Oct. 14, 2015). Here, Plaintiff alleges in conclusory fashion that Defendants “purposefully and wrongfully disrupted the contractual relationship that existed” between Plaintiff and MPA. Compl. ¶ 184. Plaintiff does not identify which, if any, terms of a contract were breached; he only alleges that Defendants’ conduct caused his contractual relationship with MPA to be

1 Defendants do not provide additional grounds for dismissal with respect to Plaintiff’s negligent infliction of emotional distress claim. Accordingly, this claim survives. terminated. Id. ¶ 185. Absent any allegation that terms of a contract were violated, the Court cannot find that any breach occurred.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Lama Holding Co. v. Smith Barney Inc.
668 N.E.2d 1370 (New York Court of Appeals, 1996)
Carlson v. Geneva City School District
679 F. Supp. 2d 355 (W.D. New York, 2010)
Noakes v. Syracuse Univ.
369 F. Supp. 3d 397 (N.D. New York, 2019)
Allaire Corp. v. Okumus
433 F.3d 248 (Second Circuit, 2006)
Pasternack v. Laboratory Corp. of America Holdings
807 F.3d 14 (Second Circuit, 2015)

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Schiebel v. Schoharie Central School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schiebel-v-schoharie-central-school-district-nynd-2025.