Smith v. City of New York
Charles Smith, acting pro se, filed a civil rights action under 42 U.S.C. §§ 1983, 1985, and 1986 against the City of New York and several of its departments (city defendants), and the Legal Aid Society of New York. Smith alleges constitutional violations related to his arrest, incarceration, and trial for his wife's murder, including false arrest, battery, and unconstitutional searches. He also asserts pendent state claims such as legal malpractice against Legal Aid. Legal Aid moved to dismiss all claims or for summary judgment, arguing it is not a state actor for Section 1983 purposes and that conspiracy claims were not sufficiently pled. The city defendants moved to consolidate this action with two prior cases in the Southern District of New York. The court granted in part and denied in part Legal Aid's motion, dismissing federal claims but denying dismissal of the state law legal malpractice claim. The court denied consolidation with cases in another district but, sua sponte, ordered the transfer of the entire action, including the remaining malpractice claim, to the Southern District of New York for consolidation with the related cases, finding it would serve the convenience of parties and witnesses and promote judicial efficiency.