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S.D.N.Y.Procedural orderFiled June 3, 2025

Bowman v. New York State Homes and Community Renewal

Judge
John Cronan
Docket
1:25-cv-03784
Court
U.S. District Court · Southern District of New York
Pages
3
Civil ProcedurePro Se
In one sentence

In Bowman v. New York State Homes and Community Renewal, Judge Cronan ordered service of the pro se plaintiff’s complaint through the Marshals Service.

Who this affects

Lorita M. Bowman, the defendants named in her complaint, the Clerk of Court, and the U.S. Marshals Service.

What happened

In Bowman v. New York State Homes and Community Renewal, Lorita M. Bowman sued New York State Homes and Community Renewal and other defendants under several employment-discrimination laws, alleging discrimination based on race, color, national origin, sex, disability, and age. She was proceeding without a lawyer and had been allowed to proceed without paying court fees in advance.

Because Bowman was allowed to proceed without paying fees, the court said she could rely on the court and the U.S. Marshals Service to serve the defendants. The order also extended the service deadline to 90 days after summonses are issued, rather than 90 days after the complaint was filed.

Judge John P. Cronan directed the Clerk of Court to prepare the service forms, issue summonses, and give the necessary papers to the Marshals Service. The order did not decide whether Bowman’s discrimination claims were valid. It also instructed Bowman to request more time if service is not completed within 90 days after the summonses are issued and to notify the court of any address change.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bowman v. New York State Homes and Community Renewal · No. 1:25-cv-03784
Judge
John Cronan
Date
June 3, 2025

Background

Lorita M. Bowman, proceeding without a lawyer, brought claims under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Rehabilitation Act, the Age Discrimination in Employment Act, 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York State Workers with Disabilities Law. She alleged that her employer discriminated against her based on race, color, national origin, sex, disability, and age. The opinion states that the court had granted her permission to proceed without prepaying filing fees in an order dated May 14, 2025.

Service of process

For a person allowed to proceed without prepaying fees, federal law requires the court to order the U.S. Marshals Service to serve the defendants. The court explained that Bowman could not have served the defendants until the court reviewed the complaint and ordered that summonses be issued. It therefore extended the time for service to 90 days after the summonses issue.

Order

Judge John P. Cronan directed the Clerk of Court to complete a U.S. Marshals Service Process Receipt and Return form for the defendants, issue the summonses, and provide the Marshals Service with the paperwork needed for service. The order states that Bowman should request an extension of time if the complaint is not served within 90 days after the summonses are issued. It also states that Bowman must notify the court in writing if her address changes and that the court may dismiss the action if she fails to do so. The order addressed service procedures and did not rule on the merits of Bowman’s discrimination allegations.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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