Case Summary:
Rosenthal v. Roosevelt Island Operating Corporation is a federal civil‑rights and due‑process appeal brought by former RIOC President and CEO Susan G. Rosenthal challenging the dismissal of her lawsuit against RIOC and state officials in the United States Court of Appeals under docket number 25‑1667, following oral argument on January 30, 2026.
In the underlying federal case in the Southern District of New York (No. 1:23‑cv‑09660, Judge Dale E. Ho), Rosenthal alleged that her June 2020 termination as RIOC President/CEO—officially justified by accusations that she had used offensive, “salacious” and racially charged language—was in fact retaliatory and politically motivated, tied to her efforts to raise infrastructure and safety concerns, and that she was publicly branded a racist without a meaningful chance to clear her name. She asserted a 42 U.S.C. § 1983 due‑process “stigma‑plus” claim, contending that the State of New York and RIOC violated her constitutional rights by publicly disseminating allegedly false reasons for her firing and denying her a name‑clearing hearing, and she further argued that prior state‑court Article 78 and related proceedings did not give her adequate process.
The defendants (RIOC and associated state officials) moved to dismiss primarily on res judicata and preclusion grounds, maintaining that Rosenthal had already litigated or could have litigated these issues in earlier New York state‑court proceedings (an Article 78 and a plenary state action) which ended in final judgments against her, and that federal courts must give those state judgments full faith and credit. The district court agreed, holding that New York’s transactional approach to res judicata barred her federal due‑process claims because they arose from the same nucleus of operative facts as her prior state cases; the court also held that Article 78 and related procedures provided constitutionally adequate process, and therefore dismissed her complaint under Rule 12(b)(6).
Rosenthal’s present appeal challenges that dismissal, arguing that her federal due‑process claim is not precluded by the prior state litigation and that she never received a meaningful, constitutionally sufficient opportunity to clear her name after being publicly accused of misconduct and terminated from her public‑sector leadership role.