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Schoolcraft v. City of New York

United States District Court, S.D. New York

June 28, 2013

ADRIAN SCHOOLCRAFT, Plaintiff,
v.
CITY OF NEW YORK, et al., Defendants

Page 193

For the Plaintiff: LAW OFFICE OF NATHANIEL B. SMITH, New York, NY, By: Nathaniel B. Smith, Esq.

For the City Defendants: MICHAEL A. CARDOZO, CORPORATION COUNSEL OF THE CITY OF NEW YORK, New York, NY, By: Rachel Seligman Weiss, Esq.

OPINION

Page 194

ROBERT W. SWEET, U.S.D.J.

Plaintiff Adrian Schoolcraft (" Plaintiff" or " Schoolcraft" ) has moved to enjoin[1] all further administrative proceedings by defendant the City of New York (" City" ) and the New York Police Department (" NYPD" ) against him, including the administrative hearing that had been scheduled to begin on June 17, 2013 (the " Hearing" ).

Upon the conclusions set forth below, the motion is granted.

Prior Proceedings

A detailed recitation of the facts of the case is provided in this Court's opinion dated May 6, 2011, which granted in part and denied in part Defendant Jamaica Hospital Medical Center's motion to dismiss. See Schoolcraft v. City of N.Y., No. 10 Civ. 6005 (RWS), 2011 WL 1758635, at *1 (S.D.N.Y. May 6, 2011). Familiarity with those facts is assumed.

On June 10, 2013, Plaintiff filed an order to show cause as to why an order should not be issued staying all further administrative proceedings against Plaintiff by the City and the NYPD. The Court granted the order, and temporarily stayed the administrative proceedings against Plaintiff until July 1, 2013. The parties submitted briefing on the motion, and the matter was marked fully submitted on June 19, 2013.

The Preliminary Injunction Is Granted

The instant motion presents two issues: (1) whether the outcome of the Hearing would have a preclusive effect, pursuant to the doctrine of collateral estoppel, so as to interfere with the Court's ability to fully adjudicate this action; and (2) even if so, whether the Court can and should enjoin the Hearing.

A. The Outcome of the Hearing May Preclude A Full Adjudication of the Instant Case

With respect to the first issue, " [t]he Supreme Court has held that, as a matter of federal common law issue preclusion, " when a state agency acting in a judicial capacity . . . resolves issues of fact properly before it which the parties have had an adequate opportunity to litigate, federal courts must give the agency's factfinding the same preclusive effect to which it would be entitled in the State's courts.'" Locurto v. Giuliani, 447 F.3d 159, 170 (2d Cir. 2006) (quoting Univ. of Tennessee v. Elliott, 478 U.S. 788, 799, 106 S.Ct. 3220, 92 L.Ed.2d 635 (1986)). In addition, under New York law, " collateral estoppel, or issue preclusion, gives conclusive effect to an administrative agency's quasi-judicial determination when two basic conditions are met: (1) the issue sought to be precluded is identical to a material issue necessarily decided by the administrative agency in a prior proceeding; and (2) there was a full and fair opportunity to contest this issue in the administrative tribunal." Jeffreys v. Griffin, 1 N.Y.3d 34, 39, 801 N.E.2d 404, 769 N.Y.S.2d 184 (N.Y. 2003); see also Burkybile v. Bd. of Educ., 411 F.3d 306, 310 (2d Cir. 2005) (" New York courts give quasi-judicial administrative fact-finding preclusive

Page 195

effect where there has been a full and fair opportunity to ...


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