The American Society for the Prevention of Cruelty to Animals v. Gordon Lavalette

CourtDistrict Court, S.D. New York
DecidedNovember 4, 2025
Docket1:25-cv-05016
StatusUnknown

This text of The American Society for the Prevention of Cruelty to Animals v. Gordon Lavalette (The American Society for the Prevention of Cruelty to Animals v. Gordon Lavalette) 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
The American Society for the Prevention of Cruelty to Animals v. Gordon Lavalette, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT a aap: oe |

THE AMERICAN SOCIETY FOR THE [90 PREVENTION OF CRUELTY TO ANIMALS, joveemnn A) 4/9095) lait

~apainst~ 25 civ. 5016 (CM)(KHP) GORDON LAVALETTE, Defendant. MEMORANDUM DECISION AND ORDER McMahon, J.: Gordon Lavalette served for several years as the Chief Financial Officer of The American Society for the Prevention of Cruelty to Animals (ASPCA), a widely recognized and respected charitable organization that, for 150 years since its founding in 1866, has promoted the welfare and rights of animals. Depending on whose papers you read, Lavalette was either a whistle-blower who uncovered and tried to report the ASPCA’s squandering of millions of dollars of donor- contributed funds on consulting contracts and media buys, or a faithless employee who orchestrated a “calculated and relentless campaign” to create the faise impression of corporate mismanagement at the ASPCA in order to divert attention from his own misconduct, which resulted in the decision to fire him. There are at present two lawsuits — one brought by each party asserting claims that arise out of this unhappy situation. One, brought by Lavalette, is pending in Essex County (New Jersey) Superior Court; the other, brought by the ASPCA, is the instant action.

Lavalette’s lawsuit was filed on May 15, 2025, The ASPCA’s lawsuit was filed on June 13, 2025, less than a month later. Lavalette’s complaint contends that he was fired in retaliation for his engaging in whistleblower activities, in violation of the New Jersey Conscientious Employee Protection Act (CEPA) and New York’s whistleblower statute, N.Y. Labor Law §740. He also alleges that his former employer defamed him by falsely criticizing his performance in front of ASPCA executives. The ASPCA’s complaint argues that Lavalette violated his fiduciary obligations and duty of loyalty to the ASPCA by filing bad-faith, vexatious, and harassing internal complaints for the improper purpose of securing an undeserved separation payment. The ASPCA tried to remove Lavalette’s action to my sister court in the District of New Jersey, but that court granted Lavalette’s motion to remand the case to state court, where it presently sits. Lavalette originally brought an anti-suit injunction motion in the Essex County Superior Court, but has thought better of it and withdrawn that application. Lavalette has moved to dismiss (without prejudice) or stay this lawsuit pending litigation in New Jersey. He argues that his was the first-filed action, so the parties’ dispute should be litigated in his chosen forum. The ASPCA opposes his motion. Because New York is the undoubted center of gravity of this dispute and no significant steps have been taken to litigate this matter on the merits in New Jersey, the ASPCA’s lawsuit should be litigated here. Lavalette’s motion for dismissal or a stay of proceedings in this action is DENIED. The First Filed Rule The first-filed rule states that, in determining proper venue, “where there are two competing lawsuits, the first suit should have priority.” D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (quoting First City Nat'l Bank & Trust v. Simmons, 878 F.2d 76, 79 (2d Cir.1989)).

However -- and significantly for this case — the first-filed rule applies only to concurrent lawsuits pending in two different federal courts. A first-filed lawsuit filed in a state court is no bar to proceedings filed in a federal court. As between state and federal courts, the rule is that the pendency of an action in the state court is no bar to proceedings concerning the same matter in the federal court having jurisdiction. Colorado River Water Conservation District v. United States, 424 US. 800, 817 (1976). Lavalette filed his lawsuit in a New Jersey state court. The ASPCA filed its lawsuit in this court. Although the claims in suit in this action arise under state law, this court has undoubted jurisdiction over the dispute between the ASPCA -- a New York corporation — and its employee —

a citizen of New Jersey. Therefore, the “first-filed” rule is inapplicable. Were any doubt on that score created by virtue of the ASPCA’s abortive effort to remove Lavalette’s lawsuit to the United States District Court for the District of New Jersey, that doubt was eliminated when my New Jersey colleague decided to remand Lavalette’s lawsuit to the court from whence it came — the Essex County Superior Court. So we have a state case and a federal case, and it does not matter whether the former or the latter was filed first, since “the court’s remand of the removed action to state court.,...tender[s] the first-filed rule inapplicable because ‘the first- to-file doctrine applies to concurrent federal litigation—not concurrent state/federal litigation.’”! Bull v, Howard, 204 WL 1588389, at *3 (W.D.N.Y. March 20, 2024), The only issue is whether this court should abstain from exercising jurisdiction in favor of allowing the New Jersey state court to do so. It should not and it wiil not.

1 Because Lavalette’s lawsuit was remanded to the New Jersey Superior Court, the Defendant’s motion to transfer this case to New Jersey pursuant to 28 U.S.C, §1404fa) is effectively moot.

Colorado River Abstention A federal court’s obligation to hear and decide a case over which it has jurisdiction is “virtually unflagging.” Spring Communications, Inc. v. Jacobs, 571 U.S. 69, 77 (2013); Colorado River, 424 U.S. at 817. Under the Colorado River exception, the court may abstain in order to conserve federal judicial resources only in “exceptional circumstances” where the resolution of existing concurrent state-court litigation could result in “comprehensive disposition of litigation.” Woodford v. Community Action Agency of Green County, Inc., 239 F. 3d 517, 522 (2d Cir, 2001). In determining whether this is one of the rare cases in which Colorado River abstention would be appropriate, I am required to consider the following six factors: 1. Whether the controversy involves a res over which one of the courts has assumed jurisdiction; 2. Whether the federal forum is less inconvenient than the other for the parties; 3. Whether staying or dismissing the federal action will avoid piecemeal litigation; 4, The order in which the lawsuits were filed and whether proceedings have advanced in one forum further than in the other; 5. Whether federal law provides the rule of decision; and 6. Whether state procedures are adequate to protect the plaintiff’s federal rights. However, as the Second Circuit made clear in Woodford, the balance is to be weighted heavily in favor of exercising jurisdiction. Neither of these lawsuits involves a “res” over which either court has assumed jurisdiction. Lavalette’s lawsuit does not seek to determine the ownership of any piece of property or other thing. Therefore, the first factor does not favor abstention.

The convenience factor is neutral. The ASPCA and all its records are in New York City □□ it has no offices in New Jersey at all, let alone in Essex County — and it appears that, while Lavalette lives in New Jersey (albeit not in Essex County, apparently”), he worked primarily in New York City — at least, I can infer as much since he applied for and received unemployment benefits from the State of New York. But Essex County, New Jersey, where Lavalette filed his lawsuit, is but a few miles, as the crow flies, from Manhattan, where the ASPCA is located. I will not pretend that, in this day and age of electronic discovery, it would seriously inconvenience the parties to litigate in either state. But that does not help Lavalette’s cause, for if'a factor is neutral, it cannot be counted in favor of abstention.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
The American Society for the Prevention of Cruelty to Animals v. Gordon Lavalette, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-american-society-for-the-prevention-of-cruelty-to-animals-v-gordon-nysd-2025.