Stachurska v. SSA 48th Str.

Background

Lucja Stachurska, representing herself, sued SSA 48th Str. and SSA 12th Str., two Social Security Administration offices in Manhattan. She indicated that she receives Supplemental Security Income benefits, but stated that an unspecified incident caused her benefits either not to be paid or to be reduced. She attached correspondence from the Social Security Administration verifying her benefits.

Stachurska also stated that she had lived in a shelter but that the “shelter company refuse[d] me any place to live.” She attached a police report concerning a complaint about an incident on January 12, 2025. The opinion does not identify the individuals or entities involved in the housing issue or police complaint.

Court’s analysis

Because Stachurska was proceeding without paying filing fees, the court explained that it had to dismiss any claim that was frivolous, malicious, failed to state a claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also said it must interpret self-represented pleadings liberally.

The court held that the complaint did not satisfy Federal Rule of Civil Procedure 8 because it did not allege facts showing that Stachurska was entitled to relief from the named defendants. Because she named Social Security Administration offices, referred to SSI benefits, and attached Social Security Administration correspondence, the court interpreted the complaint as seeking review of a Social Security decision.

The court explained that federal judicial review under Section 405(g) of the Social Security Act generally requires a final decision by the Commissioner of Social Security after a hearing. The administrative process ordinarily includes an initial benefits determination, reconsideration, a hearing before an administrative law judge, and review by the Appeals Council. The court stated that failure to complete this process may be excused only in limited circumstances.

The court separately stated that any housing or police-related claims could be brought in a new civil action against defendants who allegedly violated Stachurska’s rights, with facts describing each defendant’s conduct. It also noted that defendants may be joined in one action only when the claims arise from the same transaction or occurrence, or series of transactions or occurrences, and share a common legal or factual question.

Order

The court granted Stachurska leave to file an amended complaint within 60 days. It directed her to use the court’s form for Social Security actions under Section 405(g) and to provide:

- the date of the administrative law judge’s decision; - the date of the Appeals Council letter; - the date she received that letter; and - a copy of the Appeals Council letter.

If she had not exhausted her administrative remedies, the court directed her to include facts explaining why exhaustion should be excused. The amended complaint must completely replace the original complaint, so any facts or claims she wishes to preserve must appear in the amended complaint.

The court did not dismiss the action in this order. It stated that if Stachurska failed to comply within the permitted time and could not show good cause, it would dismiss the action for failure to exhaust administrative remedies, without prejudice to filing a new action after exhaustion. No summons would issue at that time. The court also denied permission to appeal without prepaying fees, certifying that an appeal would not be taken in good faith.