NYC's Victims of Gender-Motivated Violence Law in the Second Circuit

Doe v. Black (S.D.N.Y. #1:23-cv-06418) and Parker v. Alexander (S.D.N.Y. #1:24-cv-04813) are landmark Second Circuit appeals testing the interplay between New York City’s Victims of Gender-Motivated Violence Protection Law (VGMVPL)—a local ordinance enabling civil suits for gender-based violence with a revived lookback window enacted in 2022—and the state’s broader Adult Survivors Act (ASA) and Child Victims Act (CVA), which similarly revive time-barred sexual assault claims but with distinct scopes and timelines.

Stalled Litigation

Several civil lawsuits in U.S. District Court and New York Supreme Court are stayed pending the outcome of the appeals, including several against Sean Combs:

• McKinney v. Combs

• Lampros v. Combs

• English v. Combs

• Graves v. Combs

• Doe v. Combs 1:24-cv-07776

• Doe v. Combs 1:24-cv-07774

• Doe v. Combs 1:24-cv-07778

• Doe v. Combs 1:24-cv-08812

• Doe v. Combs 1:24-cv-08808

• Doe v. Combs 1:24-cv-08813

• Doe v. Combs 1:24-cv-09852

• Haffoney v. Combs

Doe v. Black

In Doe v. Black, filed in July 2023 by an anonymous plaintiff alleging that financier and Jeffrey Epstein associate Leon Black sexually assaulted her in 2002 when she was 16, the district court under Judge Jessica G. L. Clarke denied Black’s motion to dismiss in September 2024, holding that the VGMVPL’s revival provision is not preempted by the CVA’s child-specific framework and allowing the local ordinance to coexist with state revival statutes; Black has appealed in the Second Circuit (No. 25-564), challenging the law on preemption and constitutional grounds.

Parker v. Alexander

Conversely, Parker v. Alexander, initiated in June 2024 by plaintiff Angelica Parker against brothers Tal, Alon, and Oren Alexander (real estate developers and brokers), accuses the defendants of sexually assaulting her in 2016 at a Manhattan party, invoking the VGMVPL for claims of battery, assault, and infliction of emotional distress amid alleged coercion tied to professional networking. Judge Lewis A. Kaplan granted the Alexanders’ motion to dismiss on January 22, 2025, dismissing the VGMVPL claim based on his reading of New York’s adult-survivor revival framework and concluding that the state’s Adult Survivors Act occupies the field for adult revival claims; Parker has appealed (2d Cir. No. 25-487), arguing that the ASA complements rather than overrides the VGMVPL’s gender-motivated focus.

Oral Arguments

The appeals, consolidated for coordinated briefing and argument on an expedited calendar, have attracted amicus participation from the City of New York and advocacy groups on both sides.

On December 17, 2025, a Second Circuit appellate panel heard arguments.

In addition to the question of NYC’s law being preempted by NY State law, is the question of whether the Second Circuit will decide or seek certification from the State court, which could create further delays for the cases already stayed.