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 (TRS), the Board of Education of the City School District of the City of New York (BOE), and Patricia Reilly, Sanford R. Rich, and Melanie Whinnery. He alleged that Defendants discriminated and retaliated against him because of his race and because he participated as a class member in an earlier class action involving the Board of Education’s use of a teacher-qualification test.

Oparaji alleged that the earlier case entitled him to pension-related relief based on a counterfactual service history—the service history he would have accrued absent discrimination. His individual judgment stated that this service ran from April 1998 through February 16, 2001, a period of two years and nine months. Oparaji claimed that he also had prior teaching service from January 1996 through April 1998, which he argued gave him more than five years of service and made him eligible for a vested pension. The court noted that the complaint contained no factual support for the claimed prior service. Oparaji also acknowledged that he withdrew his TRS contributions in 2009.

The Second Amended Complaint asserted claims for race discrimination under 42 U.S.C. § 1981, employment discrimination and retaliation under Title VII of the Civil Rights Act of 1964, breach of contract, fraud, negligence, fraudulent concealment, breach of fiduciary duty, an alleged violation of New York retirement-system regulations, and declaratory relief.

The Section 1981 and Section 1983 Claims

The court granted Defendants’ motion to dismiss Oparaji’s § 1981 claims against BOE and the individual defendants as unopposed and on the merits. Section 1981 does not provide a separate private cause of action against state actors; courts instead evaluate such claims under 42 U.S.C. § 1983, which provides a cause of action for deprivation of federal rights under color of state law.

Even construing Oparaji’s § 1981 claims as § 1983 claims, the court held that they failed to state a claim. A claim against a municipal entity or an official sued in an official capacity must plausibly allege that the deprivation resulted from a municipal policy or custom. The court found that the complaint did not do so as to BOE, the individual defendants, or TRS.

The court also held that Oparaji did not adequately allege that the individual defendants were personally involved in denying his pension benefits. Rich and Whinnery were executives of pension systems separate from TRS, and the complaint did not explain their personal involvement in the alleged denial. As to Reilly, the complaint’s allegations that she signed the earlier Pension Order and failed or refused to comply with court orders were conclusory and did not adequately connect her to the denial of benefits.

The court further held that Oparaji had not plausibly alleged deprivation of a qualifying pension right. The earlier Pension Order limited pension relief to the counterfactual service history in each class member’s individual judgment. Oparaji’s judgment reflected two years and nine months of counterfactual service, not the five years required for vesting under the New York City Administrative Code. The court also relied on Oparaji’s acknowledgment that he had withdrawn his accumulated contributions, which under the cited provision meant that he did not have a vested retirement right. The court therefore dismissed the § 1981 claims against all Defendants, including to the extent they were construed as § 1983 claims.

The Title VII Claims

The court dismissed Oparaji’s Title VII claims against the individual defendants because individuals cannot be held liable under Title VII. It then considered the claims against TRS and BOE.

In New York, a person asserting a Title VII claim generally must file a complaint with the Equal Employment Opportunity Commission within 300 days of the alleged unlawful employment action. Oparaji filed his administrative charge on July 22, 2024. Although the complaint did not clearly state when he learned of the alleged discrimination and retaliation, the court conservatively treated June 2022—when a TRS representative allegedly told him that he did not qualify for pension benefits—as the relevant date. Because that date was well more than 300 days before the administrative filing, the court dismissed the Title VII discrimination and retaliation claims as time-barred.

State-Law Claims and Disposition

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning its authority over related state-law claims, and did not resolve the merits of Oparaji’s state-law claims.

The court did not address Defendants’ separate arguments that the case should be dismissed for lack of subject-matter jurisdiction or because Oparaji had signed a release in the earlier class-action matter. Judge Kimba M. Wood granted Defendants’ motion to dismiss, directed the Clerk to close the pending motion, and directed the Clerk to close the case.