Samuels v. The Urban Assembly, Inc.

Background

Melissa Samuels was a math teacher at Urban Assembly Charter School for Computer Science, which the opinion also calls UACS or the School. On June 9, 2022, a student struck Samuels in the head with a ball during class. She called 911, reported the incident to police, went to a hospital, and later obtained a note excusing her from work until June 21. She described the incident as an assault, while David Noah, then the School’s principal, described it as an accidental hit with a foam ball.

Noah disabled Samuels’s access to the School’s electronic systems after the incident. He later asked to discuss the matter and requested more information about her medical condition. Samuels did not provide additional information or discuss the incident with School personnel. On June 16, 2022, UACS terminated her employment, citing concern for students and families, her lack of communication, and recent attendance issues.

Samuels asserted claims under the Americans with Disabilities Act (ADA), the New York State Human Rights Law, the New York City Human Rights Law, and the New York Labor Law. Before the court was the defendants’ motion for summary judgment, which asks the court to enter judgment without a trial when the evidence shows no genuine dispute requiring a jury’s decision.

ADA Discrimination and Failure to Accommodate

The court granted summary judgment on Samuels’s ADA discrimination and failure-to-accommodate claims. To proceed on those claims, Samuels had to show that she had an ADA disability—an impairment that substantially limits one or more major life activities.

The court acknowledged that Samuels had been diagnosed with a minor head injury, neck pain, and a concussion, and that these conditions might qualify as impairments. But it found that the hospital records, doctor’s note, and Samuels’s testimony did not establish a substantial limitation. The medical records did not describe significant limits on activities such as concentrating, sleeping, or performing daily tasks. The doctor’s note only excused her from work for ten days and did not explain her condition or accommodation needs. The court also found Samuels’s testimony too general to establish a substantial limitation.

Because Samuels did not show that she was disabled under the ADA, the court concluded that she could not establish the required initial case for discrimination or failure to accommodate.

ADA Retaliation

The court also granted summary judgment on Samuels’s ADA retaliation claim. It assumed that Samuels had established the initial elements of retaliation because requesting a reasonable accommodation is protected activity, UACS knew about her request, her termination was an adverse action, and the termination occurred six days after the request.

UACS offered legitimate, non-retaliatory reasons for the termination: Samuels’s decision to report the incident to police and her failure to communicate with School officials after initially requesting leave. The court found those reasons supported by the termination email, Noah’s testimony, and other employee testimony.

The court then found that Samuels had not shown that these reasons were a pretext, meaning a false explanation hiding retaliation. It rejected her arguments based on the timing of the termination, alleged inconsistencies in UACS’s explanations, Noah’s conduct and statements, and alleged departures from School procedures. The court emphasized that Samuels herself argued that the police report—not her leave request—was the driving factor behind the termination. The court concluded that the evidence showed termination largely resulted from the police report and Samuels’s later lack of communication, rather than her accommodation request.

State and City Claims

The court declined to exercise supplemental jurisdiction over Samuels’s remaining state and city claims after resolving all of her federal claims. It dismissed those claims without prejudice, leaving them for New York courts to determine. The Clerk of Court was directed to terminate the pending motions and close the case.

Disposition

The defendants’ motion for summary judgment was granted with respect to Samuels’s ADA claims. The court declined supplemental jurisdiction over the remaining state and city claims, which were dismissed without prejudice.