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Doe v. Columbia University, Slip Copy, 2024 WL 3454839

Facts

The case involves a pro se plaintiff who filed motions regarding the reassignment of Doe v. Hunter, which was accepted as related to two other actions involving Columbia University. The plaintiff sought to retain authority over the other cases and opposed the consolidation of the actions. The court noted that there was a delay in docketing the motions due to the volume of pro se cases and the need for electronic filing training. Ultimately, the court denied the plaintiff's motions as moot since the reassignment had already been accepted.

On July 1, 2024, counsel for Columbia University filed a letter informing the Court as to the possible relatedness of Doe v. Hunter, No. 23 Civ. 10394, to two pro se actions brought by Plaintiff that are pending before the Court, Doe v. Columbia Univ., No. 23 Civ. 10393, and Doe v. Kachalia, No. 23 Civ. 10395.

Issue

Whether the court should accept the reassignment of Doe v. Hunter as related to other actions and whether the plaintiff's motions regarding this reassignment should be granted.

Rule

Under Rule 13(a) of the Court's Rules for the Division of Business Among District Judges, relatedness of civil actions is determined by considering factors such as the similarity of parties, factual overlap, potential for conflicting orders, and the risk of duplication of effort and expense.

Under Rule 13(a) of this Court's Rules for the Division of Business Among District Judges, when determining the relatedness of civil actions filed in the court, judges consider whether: (A) the actions concern the same or substantially similar parties, property, transactions, or events; (B) there is substantial factual overlap; (C) the parties could be subjected to conflicting orders; and (D) whether absent a determination of relatedness[,] there would be a substantial duplication of effort and expense, delay, or undue burden on the court, parties, or witnesses.

Analysis

The court found that there was substantial factual overlap between the cases, as they involved the same plaintiff and Columbia University as a defendant. The court also noted that the parties could be subjected to conflicting orders if the cases were not treated as related. Therefore, the court concluded that the reassignment was appropriate and denied the plaintiff's motions.

Conclusion

The court denied the plaintiff's motions regarding the reassignment and consolidation of the cases, affirming the acceptance of the reassignment as related.

Accordingly, the Court also DENIES these motions as well, without prejudice to any future request to consolidate the three related actions by any of the parties or by the Court.

Who won?

The court ruled in favor of the defendants by denying the plaintiff's motions. The court reasoned that the reassignment of Doe v. Hunter as related to the other actions was justified due to the substantial factual overlap and the potential for conflicting orders. The court emphasized that the motions were moot since the reassignment had already been accepted.

The Court DENIES these motions as moot, since the Court has already accepted the reassignment of the present action as related to those other actions.

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