Williams v. Dudley

Background

Isaac J. Williams brought claims under the Americans with Disabilities Act of 1990 (ADA), the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL) against Jacqueline Dudley, Samuel Salnave, the New York City Human Resources Administration, and other defendants identified in the complaint. Magistrate Judge Robyn F. Tarnofsky issued a Report and Recommendation proposing different dispositions for the claims. The parties did not file objections before the deadline expired.

Although the lack of objections ordinarily led the court to review the recommendations for clear error, Judge Cronan stated that he reviewed the Report and Recommendation de novo—that is, independently—and found it well reasoned and well founded. The court adopted it.

Rulings

The court dismissed Williams’s ADA claims without prejudice to the extent they were asserted against the New York City Human Resources Administration. It dismissed the ADA claims with prejudice to the extent they were asserted against Jacqueline Dudley and Samuel Salnave. The court stated that these dismissals were based on failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), for the reasons given in specified parts of the Report and Recommendation.

The court declined to exercise supplemental jurisdiction over the NYSHRL and NYCHRL claims and dismissed those causes of action without prejudice. Supplemental jurisdiction is the court’s authority to hear related state-law claims alongside federal claims. Because the court dismissed the state and city claims for lack of supplemental jurisdiction, it did not decide whether those claims also failed to plausibly allege aiding-and-abetting liability or supervisory responsibility against Dudley and Salnave.

Amendment and Right-to-Sue Letter

Williams may file an amended complaint by April 17, 2025, to address the pleading deficiencies identified in the Report and Recommendation. He may replead only claims dismissed without prejudice. The court cautioned that an amended complaint would replace, rather than supplement, the existing complaint.

The court declined to require Williams to attach a copy of his ADA right-to-sue letter to an amended complaint. It stated that the ADA’s administrative-exhaustion and timeliness requirements operate as affirmative defenses rather than as claim elements or jurisdictional requirements that must be pleaded at the initial stage. The court noted that Williams could attach the letter voluntarily for completeness.

Other Disposition

The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied fee-free appeal status. It directed the Clerk of Court to close the motion at Docket Number 21.