Nampiaparampil v. New York City Campaign Finance Board

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK XAVIER JOSEPH NAMPIAPARAMPIL, Plaintiff, 25-CV-1346 (JPO) -v- ORDER NEW YORK CITY CAMPAIGN FINANCE BOARD, et al., Defendants. J. PAUL OETKEN, District Judge: This action commenced on February 14, 2025, when Plaintiff Xavier Joseph Nampiaparampil, proceeding pro se, sued Defendants New York City Campaign Finance Board (“CFB”), New York City Department of Sanitation Enforcement Division, City of New York, and the General Counsel of the CFB for statutory and constitutional claims relating to various campaign-finance and sanitation enforcement actions. (See ECF No. 1.) As Plaintiff notes in his amended complaint (see ECF No. 4 ¶ 14), the Judicial Panel on Multidistrict Litigation (the “JPML”) has ordered a hearing set for March 27, 2025 to consider whether to consolidate two related cases under the Multidistrict Litigation Statute, 28 U.S.C. § 1407 . (See In re Mary & Devi Nampiaparampil Litig., MDL No. 3146 (“MDL 3146”), ECF No. 14.) Submissions of related (or “tag-along”) actions are due in that proceeding no later than March 20, 2025. (See MDL 3146, ECF No. 13.) On February 19, 2025, the two pro se plaintiffs in the actions already under consideration for consolidation informed the JPML of this action as a “related case” and requested it also be considered for consolidation. (See MDL 3146, ECF Nos. 15, 16.) “[T]he power to stay proceedings is incidental to the power inherent in every court to control the disposition of causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936); see also Clinton v. Jones, 520 U.S. 681 (1997) (same). In determining whether to grant such a stay, district courts consider “(1) the private interests of the plaintiffs in proceeding expeditiously with the civil litigation as balanced against the prejudice to the plaintiffs if delayed; (2) the private interests of and burden on the defendants; (3) the interests of the courts; (4) the interests of persons not parties to the civil litigation; and (5) the public interest.” Youngbloods v. BMG Music, No. 07CV-2394, 2011 WL 43510 (S.D.N.Y. Jan. 6, 2011) (quoting Kappel v. Comfort, 914 F. Supp. 1056, 1058 (S.D.N.Y. 1996)). “The power to stay proceedings can be exercised sua sponte.” Off-White LLC v. AEUNZN, No. 21-CV-9613, 2023 WL 199483 , at *1 (S.D.N.Y. Jan. 17, 2023) (quotation marks omitted). “TW |here a multi-district litigation proceeding has been established, courts have routinely stayed motions pending rulings by the JPML.” Royal Park Invs. SA/NV v. Bank of Am. Corp., 941 F. Supp. 2d 367, 370 (S.D.N.Y. 2013). This case is even more straightforward, since Plaintiff apparently seeks MDL consolidation, there are no pending motions, and Defendants have yet to appear. Therefore, the private interests weigh in favor of a stay, no burden will fall to Defendants, and the interests of the courts and the public compel waiting to avoid duplicative judicial proceedings. See Royal Park Invs., 941 F. Supp. 2d at 371-74 . Accordingly, this action is hereby STAYED pending the JPML’s final order regarding consolidation in MDL No. 3146. SO ORDERED. Dated: February 24, 2025 New York, New York United States District Judge