This column discusses recent noteworthy decisions of the U.S. District Court for the Northern District of New York. This installment addresses a decision by U.S. District Judge Mae A. D’Agostino mapping the boundaries of a defamation claim and a decision by Senior U.S. District Judge Frederick J. Scullin Jr. exploring the requirements to maintain standing throughout an action.

U.S. District Court Judge Mae A. D’Agostino Dismisses Defamation Claims. Defamation claims usually involve colorful behavior, but they do not always amount to legally redressable claims. Valada v. Cucciniello, 3:22-CV-00703 (MAD/ML), 2023 WL 2895225 (N.D.N.Y. Apr. 10, 2023) is one of those cases. There, the plaintiff, Maribeth Valada, alleged that her property manager boss, defendant Armand Cucciniello, sexually harassed her and then, after she sent a demand letter and threatened to sue him, hired private investigators to smear her and intimidate witnesses. She alleged that Cucciniello and the defendant investigators falsely suggested to witnesses that she was promiscuous and dishonest and that they unlawfully threatened to subpoena these witnesses, even though there was no legal action pending at the time. She claimed that the defendants defamed her and intentionally inflicted emotional distress. After removing the case to federal court, the defendants moved to dismiss the complaint.