Jackson v. Federal Express, No. 12-1475 (2d Cir. 2014)Annotate this Case
Plaintiff appealed from the grant of summary judgment dismissing her medical leave, disability, employment discrimination, and retaliation claims and denial of her pro se request to reopen discovery. The court affirmed the judgment and clarified the obligations of a district court in granting judgment under Federal Rule of Civil Procedure 56. The court held that when a party, whether pro se or counseled, fails to respond to an opponent's motion for summary judgment, a district court may not enter a default judgment. Rather, it must examine the movant's statement of undisputed facts and the proferred record support and determine whether the movant is entitled to summary judgment. Where a partial response to a motion is made, a distinction between pro se and counseled responses is appropriate. In all cases in which summary judgment is granted, the district court must provide an explanation sufficient to allow appellate review. In this case, the district court fulfilled all these requirements. The court held that Vermont Teddy Bear v. 1-800 Beargram Co. has no bearing on this case. Accordingly, the court affirmed the district court's judgment on this matter and also affirmed the denial of plaintiff's pro se motion to reopen discovery.