Adams v. City of New York

Background

Seson Deon Teleo Adams filed the action without a lawyer. His amended complaint asserted claims under the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Rehabilitation Act, the Family and Medical Leave Act, the Health Insurance Portability and Accountability Act, and New York State Human Rights Law. He alleged wrongful termination and retaliation, along with constitutional claims concerning arrests, prosecution, due process, equal protection, and other events. The court treated the constitutional claims as claims under 42 U.S.C. § 1983.

Adams sued the State of New York, the City of New York, the New York City Comptroller’s Office, various state and city entities, judges, prosecutors, attorneys, police officers, and private parties. The complaint described events from 2014 through 2025 involving Adams’s employment, alleged arrests and protective orders, Family Court proceedings, a hospital stay, detention, and financial and tax-related matters. He also filed motions for a preliminary injunction, summary judgment, and a writ challenging officials’ authority.

Why the Court Dismissed Most Claims

Because Adams was proceeding without a lawyer and without paying filing fees in advance, the court screened the complaint under 28 U.S.C. § 1915. The court explained that such a complaint must be dismissed if it is frivolous, fails to state a claim, seeks relief from an immune defendant, or raises claims over which the court lacks jurisdiction. It also applied Federal Rule of Civil Procedure 8, which requires a short and plain statement showing that the plaintiff is entitled to relief.

The court held that Adams improperly joined unrelated claims against 75 defendants. Rule 18 generally allows a plaintiff to bring multiple claims against one defendant, while Rule 20 allows multiple defendants to be joined only when the claims arise from the same transaction or series of transactions and share common legal or factual questions. The court found that Adams’s employment claims, arrest claims, court-related claims, hospital claims, detention claims, and financial claims involved different events, witnesses, and evidence.

The court therefore severed Adams’s claims against every defendant other than the New York City Comptroller’s Office and dismissed those claims and defendants without prejudice. This means the order did not bar Adams from bringing those claims in separate actions. The court also noted that some claims might be time-barred and that some defendants, including judges and prosecutors acting within protected official roles, might be immune from damages claims.

Employment Claims

The court identified Adams’s employment-related claims as the main claims that could remain in this action. It explained that employment discrimination laws prohibit an employer from taking adverse action because of a protected characteristic or retaliating against an employee who opposed unlawful discrimination.

The court found that the amended complaint did not provide a short and plain statement of Adams’s claims against the New York City Comptroller’s Office. In particular, Adams did not explain what his disability was, what accommodations he requested, or what the employer did or failed to do because of a protected characteristic. The allegations were mixed together with allegations about many unrelated events and defendants.

The court granted Adams 60 days to file a Second Amended Complaint limited to claims arising from his employment with the New York City Comptroller’s Office. The new complaint must include only claims and defendants that properly belong together. The court directed the Clerk of Court to provide an employment-discrimination complaint form and stated that the employment claims would be dismissed for failure to state a claim if Adams did not submit adequate allegations. If Adams failed to file the new complaint on time without good cause, the court would direct the Clerk to enter judgment in the action.

Pending Motions and Disposition

The court denied Adams’s motion for a preliminary injunction because he could not show a likelihood of success on claims that had been dismissed from this action, and his employment allegations did not establish entitlement to the extraordinary remedy he requested, including restoration to his former employment. The court also denied his motions for summary judgment and a writ challenging officials’ authority.

The court directed the Clerk to terminate all defendants except the New York City Comptroller’s Office and to terminate the pending motions. It certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The matter was to remain open until a civil judgment was entered.