Tatas v. Ali Baba's Terrace Inc.

CourtCourt of Appeals for the Second Circuit
DecidedNovember 6, 2025
Docket24-1543-cv
StatusUnpublished

This text of Tatas v. Ali Baba's Terrace Inc. (Tatas v. Ali Baba's Terrace Inc.) 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
Tatas v. Ali Baba's Terrace Inc., (2d Cir. 2025).

Opinion

24-1543-cv Tatas v. Ali Baba’s Terrace Inc.

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 6th day of November, two thousand twenty-five.

PRESENT: JOSÉ A. CABRANES, MICHAEL H. PARK, STEVEN J. MENASHI, Circuit Judges. _____________________________________

Mehmet Emin Tatas, Plaintiff-Appellant,

v. 24-1543-cv

Ali Baba’s Terrace Inc., Ali Riza Dogan, Senol Bakir, Tolgahan Subakan, Defendants-Appellees,

Admiral Insurance Company, Defendant. _____________________________________

FOR PLAINTIFF-APPELLANT: Mehmet Emin Tatas, pro se, Lynbrook, NY.

FOR DEFENDANTS-APPELLEES: Diane Krebs, Jackson Lewis P.C., Melville, NY.

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

Southern District of New York (Edgardo Ramos, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the judgment of the district court is

AFFIRMED.

Mehmet Emin Tatas, pro se, appeals from the district court’s judgment

following a jury verdict in his favor on his assault and battery claim and

otherwise in favor of his former employer, Ali Baba’s Terrace Inc. (“ABT”); ABT’s

owner, Ali Riza Dogan; and former coworkers Senol Bakir and Tolgahan

Subakan. Tatas alleged that Defendants discriminated and retaliated against

him and subjected him to a hostile work environment based on his race and

national origin, in violation of 42 U.S.C. § 1981 and state and local law. He also

alleged that Dogan assaulted and battered him. We assume the parties’

2 familiarity with the remaining facts, the procedural history, and the issues on

appeal.

I. Evidentiary Rulings

“We review a district court’s evidentiary rulings for abuse of discretion,

and will reverse only if an erroneous ruling affected a party’s substantial rights.”

Marcic v. Reinauer Transp. Cos., 397 F.3d 120, 124 (2d Cir. 2005).

Tatas first argues that the district court improperly (1) denied him the

ability to introduce two documents (a response to interrogatories and a

document request) and (2) precluded him from testifying that a New York State

Department of Labor (“DOL”) employee told him to record his conversations

with Dogan. Neither argument suggests an abuse of discretion.

First, Tatas does not cite any portion of the record showing that the district

court prevented him from introducing the referenced documents, and

Defendants assert that Tatas’s counsel never sought their admission. Second,

the district court precluded testimony about the DOL employee because Tatas’s

testimony was complete without adding this information and because it would

have created confusion about why a DOL employee was advising Tatas. Given

3 these concerns that the testimony would be more prejudicial than probative, the

district court did not abuse its discretion by excluding it. See Fed. R. Evid. 403.

Tatas next argues that the district court improperly permitted defense

counsel to ask about his immigration to the United States when it precluded such

questions with respect to Subakan. This argument fails as well. The district

court’s reasoning for excluding the testimony was sound: Subakan’s

immigration status was not relevant to the issue of why he had moved out of

Tatas’s apartment. By contrast, the questions about Tatas’s immigration history

went to his overall credibility and therefore had substantially more probative

value.

Tatas also asserts that the district court erred by failing to permit witness

Eyyup Dogan from testifying about the discrimination he experienced. The

district court explained that Eyyup’s alleged sexual orientation discrimination

was not sufficiently related to Tatas’s alleged race and national origin

discrimination and would not have any probative value for any element of

Tatas’s case. The district court’s conclusion that evidence concerning Eyyup’s

allegations of discrimination would be more prejudicial than probative was thus

not an abuse of discretion.

4 Tatas further contends that the district court (1) failed to act when Eyyup

was allegedly intimidated by Ali Riza Dogan through phone calls and (2) did not

move Dogan’s seat during Eyyup’s testimony when asked. However, Tatas has

not demonstrated that either decision affected his substantial rights. Although

Tatas’s counsel represented that the phone call from Dogan during the trial

scared Eyyup, Eyyup still returned to testify for a second day. Further, there is

no indication in the record that Dogan’s seating position in the courtroom

prevented Eyyup from giving testimony or that Dogan engaged in any

intimidation in the courtroom.

II. Jury Instructions

“We review a claim of error in jury instructions de novo, reversing only

where appellant can show that, viewing the charge as a whole, there was a

prejudicial error.” Warren v. Pataki, 823 F.3d 125, 137 (2d Cir. 2016) (quotation

marks omitted). “[A]n error is harmless only if the court is convinced that the

error did not influence the jury’s verdict.” Id. (quotation marks omitted). A

party waives arguments, however, by failing to object to a jury instruction at trial.

Id. at 138. This Court “will disregard the failure to object where there is plain

error affecting substantial rights that goes to the very essence of the case, or

5 where the party’s position has previously been made clear to the trial court and

it was apparent that further efforts to object would be unavailing.” Id. at 138–

39 (quotation marks omitted).

With respect to the jury instructions, Tatas first argues that the district

court erred by permitting the jury to find only Dogan liable for assault, rather

than letting the jury consider if ABT was also liable. But Tatas did not raise this

issue at trial, and it is thus forfeited on appeal. Nor does the record reveal plain

error.

Next, Tatas contends that the jury instructions were erroneous because the

district court should have instructed the jury that (1) it could find the individual

defendants liable on the hostile work environment and retaliation claims, (2)

Defendants’ proffered explanation for their actions was pretext for

discrimination, and (3) Tatas could be awarded front pay damages. All three

arguments lack merit.

First, although Tatas’s counsel raised the issue of amending the jury

instructions to include instructions on individual liability for the hostile work

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