Obah v. City of New York
- Gregory Woods
- 1:23-cv-04997
- U.S. District Court · Southern District of New York
- 2
In Obah v. City of New York, Judge Woods granted dismissal of discrimination claims, allowed amendment, and replaced the city agency with New York City.
Patrick C. Obah, the defendants, and the City of New York, which was substituted for the Department of Administration for Children Services as a defendant. Obah may amend his complaint within 14 days after service of the order.
What happened
In Obah v. City of New York, the court reviewed a magistrate judge’s recommendation to dismiss Patrick C. Obah’s discrimination claims. The recommendation said the complaint did not state a claim under federal, New York State, or New York City discrimination laws.
No objections were filed within the allowed time. The court therefore reviewed the recommendation for obvious error and found none. It adopted the recommendation in full.
Judge Gregory H. Woods granted the defendants’ motion to dismiss, allowed Obah to file an amended complaint within 14 days after receiving the order, and directed the clerk to replace the Department of Administration for Children Services with the City of New York as the defendant.
The detailed version
- Obah v. City of New York · No. 1:23-cv-04997
- Gregory Woods
- May 30, 2024
Background
Patrick C. Obah sued the Department of Administration for Children Services and other defendants. The defendants moved to dismiss the complaint. Magistrate Judge Aaron issued a Report and Recommendation—a proposed decision for the district judge—recommending that the motion be granted, that the City of New York replace the Department of Administration for Children Services as a defendant, and that Obah be allowed to amend his complaint.
The recommendation concluded that Obah had not adequately stated a discrimination claim under 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, or the New York City Human Rights Law.
Court’s Review
Obah was served with the recommendation by mail. He had 17 days to submit written objections, including the additional time allowed for service by mail. No objection was submitted within that period. The court therefore reviewed the unobjected-to portions for clear error, meaning an obvious mistake, and found none.
Ruling
Judge Gregory H. Woods accepted and adopted the recommendation in its entirety. The court granted the defendants’ motion to dismiss. The court granted Obah leave to amend his complaint to address the deficiencies identified in the recommendation, requiring any amended complaint to be filed within 14 days after service of the order.
The clerk was directed to mail the order to Obah, substitute the City of New York for the Department of Administration for Children Services in the case caption, and terminate the pending motion at docket entry 17.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.