Williams v. NYC Board of Elections

Background

Carman Williams sued the New York City Board of Elections, Donna Ellaby, Carol Winer, Reshma Patel, Hemalee Patel, and unidentified defendants. The opinion identifies Williams as a former New York City poll inspector who had worked for the Board for approximately 14 years. She alleged retaliation under Title VII, 42 U.S.C. § 1983, the New York State Human Rights Law, and the New York City Human Rights Law. She also asserted a claim for libel per se against Hemalee Patel.

Williams alleged that she complained by email on May 31, 2022, accusing Ellaby of retaliation and calling her a racist. Williams later filed a complaint with the New York State Division of Human Rights on June 8, 2022, accusing the Board of race-based retaliation. She alleged that defendants denied her early-voting assignments and gave her negative performance reviews because of these complaints. The pleadings also stated that Ellaby had told Williams on June 1—before the administrative complaint was filed—that she would not receive early-voting assignments at that time because of reports of poor performance. Hemalee Patel later submitted the Board’s response to the administrative complaint, which referred to Williams’s alleged record of unsatisfactory performance.

Motion and Ruling

The court properly construed the defendants’ motion as a motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The motion was granted in part and denied in part.

The court granted the motion as to Williams’s Title VII claims against the individually named defendants—Ellaby, Winer, and Hemalee Patel—because the opinion states that individuals cannot be held personally liable under Title VII. The court also granted the motion as to Williams’s libel claim against Hemalee Patel. It reasoned that Patel was acting as the Board’s general counsel and that the statements in the Board’s response to the administrative investigation were covered by an absolute privilege for statements made in judicial or administrative proceedings.

The court denied the motion in all other respects because it found that the complaint contained sufficient factual allegations, accepted as true at this stage, to state plausible claims. The opinion therefore did not dismiss the remaining claims addressed by the motion. The ruling was a pleading-stage decision and did not determine whether Williams would ultimately prevail on those remaining claims.

Uncertainty

The supplied opinion text is partly corrupted at the beginning. The body consistently refers to Title VII, while one damaged line appears to read “Title VI.” The judge is identified in the text only as “Subramanian, U.S.D.J.”; a full first name is not provided.