Vanceah v. Nat'l R.R. Passenger Corp.

CourtCourt of Appeals for the Second Circuit
DecidedJune 26, 2023
Docket22-1864
StatusUnpublished

This text of Vanceah v. Nat'l R.R. Passenger Corp. (Vanceah v. Nat'l R.R. Passenger Corp.) 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
Vanceah v. Nat'l R.R. Passenger Corp., (2d Cir. 2023).

Opinion

22-1864 Vanceah v. Nat’l R.R. Passenger Corp.

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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, 2 held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of 3 New York, on the 26th day of June, two thousand twenty-three. 4 5 PRESENT: 6 MICHAEL H. PARK, 7 WILLIAM J. NARDINI, 8 ALISON J. NATHAN, 9 Circuit Judges. 10 _____________________________________ 11 12 Marjay Vanceah, 13 Plaintiff-Counter- 14 Defendant-Appellant, 15 16 v. 22-1864 17 18 Timothy Dendy, 19 Defendant-Counter- 20 Claimant-Appellee, 21 22 National Railroad Passenger Corporation, 23 DBA Amtrak, 24 Defendant-Appellee. 25 _____________________________________ 26 27 FOR MARJAY VANCEAH: René Myatt, Hollis, NY. 28 29 FOR TIMOTHY DENDY: Vikrant Pawar, Vik Pawar 30 Law PLLC, New York, NY. 31 32 FOR AMTRAK: Lisa M. Griffith, Kelly C. 1 Spina, Littler Mendelson 2 P.C., Melville, NY. 3

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

5 New York (Ramos, J.).

6 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

7 DECREED that the judgment of the district court is AFFIRMED.

8 Plaintiff Marjay Vanceah appeals from the district court’s August 1, 2022 order granting

9 in part a motion for sanctions and dismissing all of Vanceah’s claims with prejudice. Vanceah

10 brought claims under Title VII of the Civil Rights Act of 1964 and the New York City Human

11 Rights Law (“NYCHRL”) for gender discrimination and retaliation against Defendants National

12 Railroad Passenger Corporation, DBA Amtrak, and Timothy Dendy (together, “Amtrak”). Over

13 two years after the start of discovery, Amtrak moved for sanctions, including dismissal and

14 attorney’s fees, against Vanceah and her counsel “for egregious abuses of the discovery process

15 and spoliation of evidence, pursuant to Federal Rule of Civil Procedure 37 and 28 U.S.C. § 1927.”

16 Joint App’x at A-167. The district court granted the motion as to Vanceah, denied the motion as

17 to her counsel, and dismissed all of Vanceah’s claims with prejudice. Vanceah appeals from the

18 dismissal, arguing “[t]he District Court erred in dismissing Ms. Vanceah’s complaint because her

19 actions were misinterpreted or misunderstood, but they were not willful, within bad faith nor had

20 she exhibited a culpable state of mind.” Appellant’s Br. at 28. We assume the parties’

21 familiarity with the underlying facts, the procedural history of the case, and the issues on appeal.

2 1 I. Rule 28 Compliance

2 We disagree with Amtrak that Vanceah’s appeal “should be dismissed because her

3 appellate brief fails to confirm with Rule 28(a) of the Federal Rules of Appellate Procedure.”

4 Appellee’s Br. at 2. Under Rule 28(a)(8), an appellant’s brief “must contain[] appellant’s

5 contentions and the reasons for them, with citations to the authorities and parts of the record on

6 which the appellant relies.” Fed. R. App. P. 28(a)(8). Here, Vanceah’s brief is not “so deficient

7 as to amount to an invitation to the court to scour the record, research any legal theory that comes

8 to mind, and serve generally as an advocate for appellant.” Taylor v. Harbour Pointe

9 Homeowners Ass’n, 690 F.3d 44, 48 (2d Cir. 2012) (cleaned up). Vanceah cites the proper legal

10 standard for Rule 37 sanctions and directly challenges the district court’s factual finding that

11 Vanceah willfully violated discovery orders. See, e.g., Appellant’s Br. at 16 (arguing that

12 Vanceah’s failure to attach documents to an interrogatory “was an oversight,” so “[t]here was

13 nothing willful about the lapse”); id. at 17 (“[S]he was naïve, and she perhaps acted in a way to

14 protect her own integrity, but her actions were never willful or in bad faith.”). Vanceah

15 sufficiently “state[s] the issue and advance[s] an argument” against the district court’s imposition

16 of Rule 37 sanctions. Debique v. Garland, 58 F.4th 676, 685 (2d Cir. 2023) (cleaned up). We

17 thus reach the merits.

18 II. Dismissal Sanctions

19 The district court did not abuse its discretion by ordering dismissal sanctions against

20 Vanceah. Under Federal Rule of Civil Procedure 37, “[i]f a party fails to provide information or

21 identify a witness as required by Rule 26(a) or (e), . . . the court, on motion and after giving an

22 opportunity to be heard[,]” “may impose other appropriate sanctions, including” “dismissing the

3 1 action or proceeding in whole or in part.” Fed. R. Civ. P. 37(b)(2)(A)(v), (c)(1). “In imposing

2 Rule 37 sanctions, . . . courts properly consider various factors, including (1) the willfulness of the

3 non-compliant party or the reason for noncompliance; (2) the efficacy of lesser sanctions; (3) the

4 duration of the period of noncompliance; and (4) whether the non-compliant party had been warned

5 of the consequences of noncompliance.” Funk v. Belneftekhim, 861 F.3d 354, 366 (2d Cir. 2017)

6 (cleaned up). “We review a sanction of dismissal with prejudice for abuse of discretion.”

7 Shepherd v. Annucci, 921 F.3d 89, 93 (2d Cir. 2019).

8 First, the district court did not abuse its discretion by concluding that Vanceah’s discovery

9 violations were willful. “Severe sanctions may be justified when the failure to comply with a

10 court order is due to willfulness or bad faith, or is otherwise culpable.” Chevron Corp. v.

11 Donziger, 833 F.3d 74, 147 (2d Cir. 2016) (cleaned up). Willfulness may be evident when a

12 party requires “numerous extensions . . . throughout the discovery process,” continuously fails to

13 “compl[y] with written and oral discovery-related court orders,” and engages in “sustained

14 recalcitrance.” Guggenheim Cap., LLC v. Birnbaum, 722 F.3d 444, 451 (2d Cir. 2013). Over a

15 two-year period, Vanceah engaged in numerous discovery abuses. To name a few: (1) she

16 represented in an affidavit that she did not exchange any personal text messages with Dendy on

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

Related

Suzanne Taylor v. Harbour Pointe Homeowners Ass’n
690 F.3d 44 (Second Circuit, 2012)
Phelan v. Cambell
507 F. App'x 14 (Second Circuit, 2013)
Guggenheim Capital, LLC v. Birnbaum
722 F.3d 444 (Second Circuit, 2013)
Chevron Corp. v. Donziger
833 F.3d 74 (Second Circuit, 2016)
Funk v. Belneftekhim
861 F.3d 354 (Second Circuit, 2017)
San Jose Canning Co. v. Oneal
10 F.2d 100 (Ninth Circuit, 1926)
Shepherd v. Annucci
921 F.3d 89 (Second Circuit, 2019)
Embuscado v. DC Comics
347 F. App'x 700 (Second Circuit, 2009)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Vanceah v. Nat'l R.R. Passenger Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/vanceah-v-natl-rr-passenger-corp-ca2-2023.