On behalf of its client, the White Plains Housing Authority (“Housing Authority”), Keane & Beane, P.C. obtained a decision in federal court granting its motion to dismiss all federal and state law claims in Chamberlain v. City of White Plains, — F.Supp.2d —-, 2013 WL 6477334 (S.D.N.Y. Dec. 10, 2013).
In this case, Plaintiff alleged the defendants, including the Housing Authority, violated his federal civil rights pursuant to 42 U.S.C. §1983 based upon Monell liability. Specifically, Plaintiff alleged that the injuries sustained were the result of an alleged policy, practice, custom or usage of the Housing Authority to provide to the White Plains Police Department (“Police Department”) the master keys to the apartments of its tenants. In addition to his federal claims, Plaintiff brought state law claims against the Housing Authority for conscious pain and suffering, wrongful death and negligence. In connection with his claims, Plaintiff alleged that the Housing Authority, by providing a master key to the Police Department to its apartments, proximately caused injury to Plaintiff.
As reflected in the Opinion and Order, Keane & Beane, P.C. successfully demonstrated that Plaintiff failed to establish the necessary “direct causal link” between the Housing Authority’s alleged provision to the Police Department of the master keys to the apartments of its tenants and the purported violations of Plaintiff’s constitutional rights at issue in this case. The Court explained that “[t]o claim that the officers’ possession of the master key somehow proximately caused Chamberlain’s injuries is implausible.” Accordingly, the Court dismissed the Monell claim for failure to state a claim.
Based upon the same rationale — lack of causation — the Court also dismissed the state law claims against the Housing Authority. The Court found that the Housing Authority’s alleged decision to provide the Police Department with a master key to its tenants’ apartments did not proximately cause Plaintiff’s injuries, and accordingly, Plaintiff failed to make out a claim for negligence against the Housing Authority. The Court further explained that since the Housing Authority committed no underlying wrong against Plaintiff, the conscious pain and suffering and wrongful death claims also failed as a matter of law. Accordingly, the Court dismissed the state law claims in their entirety.
The Housing Authority was represented by Lance H. Klein and Jaclyn G. Goldberg.