In a decision dated June 26, 2013, Judge Eric N. Vitaliano of the United States District Court for the Eastern District of New York granted the City of Pittsfield, Massachusetts and its Police Chief Michael Wynn’s motion to dismiss the complaint. The plaintiff sought damages for false imprisonment against the defendants claiming he was improperly detained in New York due to a case of mistaken identity and based on a warrant issued in Berkshire County, Massachusetts. The City of Pittsfield and Chief Wynn moved to dismiss the complaint in the Eastern District of New York on the basis that New York lacked personal jurisdiction. In granting the motion, Judge Vitaliano found that the City of Pittsfield and Chief Wynn had established that they did not engage in a persistent course of conduct in New York and had no involvement in the decision whether or not to initiate extradition proceedings between Massachusetts and New York.

Brown v. City of New York, et al., 2013 WL 3245214 (E.D.N.Y. June 26, 2013)