Woodley v. City of New York
- Edgardo Ramos
- 1:24-cv-04864
- U.S. District Court · Southern District of New York
- 15
In Woodley v. City of New York, Judge Ramos granted the motion to dismiss the Americans with Disabilities Act claims as to all defendants.
Lynn Woodley and all named defendants. The ADA claims were dismissed, and the NYSHRL and NYCHRL claims were dismissed without prejudice without being adjudicated on their merits.
What happened
Lynn Woodley sued the City of New York and other defendants, alleging disability discrimination and retaliation under the Americans with Disabilities Act, New York State law, and New York City law. The City moved to dismiss, arguing that Woodley had not stated legally sufficient claims.
The court ruled that Woodley did not plausibly allege a disability under the federal law because her complaint focused on an inability to work at one particular front desk, rather than an inability to perform a broad class or range of jobs. The court also rejected her effort to treat the events as one continuing violation because the complaint did not assert a hostile-work-environment claim or allege a discriminatory policy or practice.
Judge Ramos granted the motion to dismiss the federal disability-law claims as to all defendants. Because those were the only federal claims, the court declined to decide the remaining state and city claims and dismissed them without prejudice, then closed the case.
The detailed version
- Woodley v. City of New York · No. 1:24-cv-04864
- Edgardo Ramos
- July 23, 2025
Background
Lynn Woodley alleged that she experienced disability discrimination and retaliation while working as a clerical associate at Harlem Hospital. She alleged that a patient repeatedly threatened and verbally assaulted her in 2019, leading to post-traumatic stress disorder (PTSD). She also alleged that she had asthma and requested various work accommodations, including remote work and reassignment away from patient-facing duties and the front desk where the earlier incidents occurred.
Woodley alleged that April Johnson, Nicole Phillips, and other hospital personnel denied or failed to provide the requested accommodations, assigned her to work at the front desk, and took other actions that aggravated her conditions. She stopped working in December 2022, filed a discrimination charge with the Equal Employment Opportunity Commission in January 2024, and was terminated later that month. Her amended complaint asserted claims under the Americans with Disabilities Act (ADA), the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL), including discrimination, retaliation, and aiding-and-abetting claims.
The City of New York moved to dismiss under Federal Rule of Civil Procedure 12(b)(6). That rule tests whether a complaint contains enough factual allegations to state a legally plausible claim; it does not ordinarily decide whether the plaintiff will ultimately win or weigh evidence.
Continuing-Violation Theory
Woodley argued in her opposition brief that the timing of her claims could be preserved under the continuing-violation doctrine, which can allow related discriminatory acts to be treated as part of an ongoing policy or practice. The court declined to consider her newly raised hostile-work-environment theory because she had not pleaded that claim in the complaint and could not use a brief opposing dismissal to amend the complaint.
The court also found that the complaint did not support an inference that the defendants’ conduct resulted from a discriminatory or retaliatory policy or practice. The alleged events included a lengthy period without offending events, from April 2021 to April 2022, and mostly involved Johnson. The court characterized the alleged conduct as a series of separate acts rather than an ongoing violation. It therefore ruled that the continuing-violation doctrine did not apply and that the only timely alleged acts were those occurring after March 11, 2023, 300 days before Woodley filed her discrimination charge.
ADA Disability Status
The ADA defines a disability to include a physical or mental impairment that substantially limits one or more major life activities, including working. When working is the relevant activity, a plaintiff generally must allege a limitation affecting a class or broad range of jobs; inability to perform one particular job is not enough.
The court concluded that Woodley’s amended complaint did not allege facts supporting a reasonable inference that she was disabled under the ADA. The complaint focused on her inability to work at the front desk and did not allege that she could not perform a class or broad range of jobs. The court also declined to rely on Woodley’s broader assertion in her opposition brief that her PTSD prevented her from working in any patient-contact role because that assertion was not adequately pleaded in the complaint.
The court therefore dismissed the ADA claims. The conclusion applied to all defendants, even though the City filed the motion, because the court stated that dismissal as to all defendants was appropriate where the federal issues concerning the other defendants were substantially the same as those concerning the City.
Remaining State and City Claims
After dismissing the ADA claims, the court declined to adjudicate Woodley’s NYSHRL and NYCHRL claims. Those were the remaining state and city claims, and the court determined that they were best left for resolution in state court after the federal claims were dismissed.
Disposition
The court granted the City’s motion to dismiss the ADA claims with respect to all defendants. The NYSHRL and NYCHRL claims were dismissed without prejudice. The Clerk was directed to terminate the motion and close the case.
Read the full 15-page opinion on CourtListener, the free public archive maintained by the Free Law Project.