Roach v. New York Housing Authority
- Clarke
- 1:23-cv-08135
- U.S. District Court · Southern District of New York
- 3
In Roach v. New York City Housing Authority, Judge Clarke adopted the recommendation, dismissing most claims and allowing amendment only for NYCHA hostile-work-environment claims.
Edmindo A. Roach’s claims against Local 237 were dismissed with prejudice. His race-based discrimination claims against NYCHA were also dismissed with prejudice, while his NYCHA hostile-work-environment claims were dismissed without prejudice and could be amended only under the three identified employment-discrimination laws.
What happened
In Edmindo A. Roach v. New York City Housing Authority and Local 237, International Brotherhood of Teamsters, both defendants asked the court to dismiss Roach’s claims. A magistrate judge recommended dismissing the claims against Local 237 and the race-based claims against NYCHA with prejudice, dismissing NYCHA hostile-work-environment claims without prejudice, and allowing amendment only of those hostile-work-environment claims.
Roach objected, arguing that Local 237’s lack of assistance and transparency prevented him from suing it earlier. He also argued that an employment-discrimination charge filed with the Equal Employment Opportunity Commission covered both defendants and that his race-based claims should continue as background for his hostile-work-environment claims. The court rejected those arguments, finding that the charge named only NYCHA and that Roach could use race-based allegations as background when amending the hostile-work-environment claims.
Judge Jessica G. L. Clarke adopted the recommendation in full. The court granted Local 237’s motion to dismiss and dismissed the claims against Local 237 with prejudice. It also granted NYCHA’s motion to dismiss, dismissed the race-based discrimination claims against NYCHA with prejudice, dismissed the hostile-work-environment claims without prejudice, and granted leave to amend only the hostile-work-environment claims under Title VII, the New York State Human Rights Law, and the New York City Human Rights Law against NYCHA.
The detailed version
- Roach v. New York Housing Authority · No. 1:23-cv-08135
- Clarke
- Aug. 22, 2025
Background
The case was referred to Magistrate Judge Netburn for general pretrial matters and dispositive motions. NYCHA and Local 237 moved to dismiss. On May 6, 2025, Magistrate Judge Netburn issued a Report and Recommendation advising that:
- the claims against Local 237 be dismissed with prejudice; - the Title VII, New York State Human Rights Law, and New York City Human Rights Law claims against NYCHA for race-based discrimination and retaliation be dismissed with prejudice; - the hostile-work-environment claims against NYCHA be dismissed without prejudice; and - Roach be denied permission to amend except as to the hostile-work-environment claims against NYCHA.
Roach filed a delayed objection. He argued that Local 237 should not receive dismissal based on the time limit because it had not assisted him at NYCHA and had not given him enough transparency to sue. He also argued that an Equal Employment Opportunity Commission charge filed on January 4, 2022, named both NYCHA and Local 237. The court noted that the charge named or referred only to NYCHA. Roach further asked to continue his race-based discrimination claim as background for his hostile-work-environment claims.
Court’s Review
The district court explained that it reviews properly challenged portions of a magistrate judge’s recommendation independently. Portions without a proper objection are reviewed for clear error, meaning an obvious mistake in the record. The court reviewed the motion papers, the Report and Recommendation, Roach’s objection, and Local 237’s response. It found the recommendation well reasoned and supported by the facts and law. The court also found that Roach’s objection, which was framed as an amended claim, did not provide a legal basis to reject the recommendation.
Disposition
The court adopted the Report and Recommendation in full. It granted Local 237’s motion to dismiss and dismissed the claims against Local 237 with prejudice. It granted NYCHA’s motion to dismiss and dismissed the race-based discrimination claims against NYCHA with prejudice. It dismissed the hostile-work-environment claims against NYCHA without prejudice. It granted Roach leave to amend only the hostile-work-environment claims under Title VII, the New York State Human Rights Law, and the New York City Human Rights Law against NYCHA. The Clerk was directed to terminate the two listed motions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.