Kowalchuck v. Metropolitan Transportation Authority, No. 22-1921 (2d Cir. 2024)
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In this case, plaintiff-appellant John Kowalchuck sued his former employer, the Metropolitan Transportation Authority (MTA), under the Federal Employers' Liability Act for injuries he sustained while clearing snow at an MTA property. The MTA requested a pre-motion conference to discuss its anticipated motion for summary judgment. The district court granted the request, and at the pre-motion conference, it deemed the MTA's motion as having been made and denied it. However, two years later, and only four days before the trial was set to begin, the district court reconsidered its previous denial of the motion and granted summary judgment in favor of the MTA, dismissing the complaint. Kowalchuck was not given an opportunity to submit papers in opposition to the motion.
The United States Court of Appeals for the Second Circuit held that the district court erred when it sua sponte reconsidered its denial of summary judgment and granted summary judgment to the MTA, without giving Kowalchuck notice or an opportunity to be heard. Therefore, the court vacated the judgment of the district court and remanded the case for further proceedings. The Court of Appeals emphasized the need for procedural safeguards such as notice and an opportunity to be heard before a court can grant summary judgment sua sponte. The court also noted that Kowalchuck was procedurally prejudiced by the district court's use of a truncated or expedited procedure, as he was surprised by the district court's sua sponte grant of summary judgment and that surprise resulted in his failure to present evidence in support of his position.
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