Oparaji v. Teachers' Retirement System of the City of New York

Background

Maurice Oparaji, proceeding without a lawyer, sued the Teachers’ Retirement System of the City of New York, the Board of Education of the City School District of the City of New York, and Patricia Reilly, Sanford R. Rich, and Melanie Whinnery. He had been a member of the class in an earlier discrimination case involving the Board of Education’s use of the Liberal Arts and Sciences Test. In that earlier case, the court approved an individual judgment for Oparaji that included $21,986 in back pay. Oparaji later signed a settlement and release agreement.

Oparaji alleged that the retirement system failed to provide pension-related relief connected to that judgment. He alleged that he paid a $2,575.65 invoice for basic member contributions but did not receive a response about his pension status. He asserted three causes of action: breach of contract based on failure to follow a pension order, retaliation for protected activity, and discrimination based on race and age. He also referenced disability discrimination.

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which addresses subject-matter jurisdiction, and Rule 12(b)(6), which addresses whether a complaint states a legally sufficient claim.

Contract Claim and Jurisdiction

The court dismissed the breach-of-contract claim for lack of subject-matter jurisdiction and stated that the dismissal was without prejudice. The court explained that the claim was governed by New York law and therefore did not itself present a federal question.

The court also rejected Oparaji’s argument that it had continuing or ancillary jurisdiction based on the earlier pension order. Although that order retained jurisdiction over disputes about the operation of its procedures, the court held that this did not extend to disputes about Oparaji’s individual judgment. The court further found that neither Oparaji’s individual judgment nor his settlement agreement expressly incorporated the pension order’s continuing-jurisdiction provision. The court noted that Oparaji was not a signatory to the pension order and that his claims were new claims based on different theories of relief.

Discrimination and Retaliation Claims

The court dismissed the Title VII and Age Discrimination in Employment Act discrimination and retaliation claims without prejudice for failure to exhaust required administrative remedies. Before bringing those claims in federal court, a plaintiff generally must file a timely charge with the Equal Employment Opportunity Commission and receive a right-to-sue letter. The court found that Oparaji’s amended complaint did not allege that he took either step. Because exhaustion was a required precondition, the court said that deciding the merits of those claims would be premature.

The opinion also states that Oparaji did not provide details identifying the nature of his disability. The court therefore said that, even if he had exhausted the required administrative remedies, the disability-discrimination allegation would be dismissed under Rule 12(b)(6) for failure to state a claim.

Disposition

Judge Kimba M. Wood granted Defendants’ motion to dismiss in its entirety. The court granted Oparaji leave to amend and directed that any amended complaint identify each legal claim and briefly state the supporting facts. The court further required him to establish subject-matter jurisdiction and show that required administrative remedies had been exhausted. Any motion to amend had to be filed by August 17, 2024.