Stokes v. Mid-Hudson Psychiatric Forensic Center
- Kimba Wood
- 1:25-cv-06730
- U.S. District Court · Southern District of New York
- 6
In Stokes v. Mid-Hudson Psychiatric Forensic Center, Judge Wood dismissed the complaint but allowed 30 days to amend its insufficient FMLA allegations.
Jahmel Stokes’s FMLA claims were dismissed because the complaint lacked supporting facts, but he may file an amended complaint within 30 days. The defendant remains identified as Mid-Hudson Psychiatric Forensic Center.
What happened
In Jahmel Stokes v. Mid-Hudson Psychiatric Forensic Center, Jahmel Stokes alleged that his employer terminated him because of an FMLA-related disability. He sought reemployment and a reasonable accommodation, and attached an Equal Employment Opportunity Commission notice permitting him to sue.
The court found that Stokes’s only allegation—that he was “[t]erminated due to FMLA disability”—did not provide enough facts to show that the defendant interfered with his FMLA leave rights or retaliated against him. The court also declined to consider any state-law claims after dismissing the federal claims.
Judge Kimba M. Wood dismissed the complaint for failure to state a claim, granted Stokes 30 days to file an amended complaint, and denied fee-free status for any appeal. The case will remain open until a civil judgment is entered.
The detailed version
- Stokes v. Mid-Hudson Psychiatric Forensic Center · No. 1:25-cv-06730
- Kimba Wood
- Sept. 24, 2025
Background
Jahmel Stokes proceeded without a lawyer and filed the action without paying the filing fee. He alleged under the Family and Medical Leave Act of 1993 (FMLA) that his employer terminated him “due to FMLA disability.” He asked the court to order the defendant to reemploy him and reasonably accommodate his disability. He also attached a May 16, 2025, Notice of Right to Sue from the Equal Employment Opportunity Commission.
Screening Standard
Because Stokes was allowed to proceed without prepaying fees, the court was required to screen his complaint. Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss an action that is frivolous or malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also must dismiss claims over which it lacks subject-matter jurisdiction. Although courts read filings by people without lawyers generously, those filings still must provide a short and plain statement showing entitlement to relief under Rule 8 of the Federal Rules of Civil Procedure.
FMLA Claims
The court explained that the FMLA generally supports two types of claims. An interference claim alleges that an employer prevented or impeded an employee from using FMLA rights. A retaliation claim alleges that an employee exercised FMLA rights or opposed unlawful conduct and then suffered an adverse employment action.
The court held that Stokes’s single conclusory sentence did not state an FMLA claim. He did not allege facts showing that he requested FMLA leave, that the defendant denied or interfered with leave, or that the defendant retaliated against him for seeking leave. The court therefore dismissed the FMLA claims for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii).
State-Law Claims
The court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—over any state-law claims Stokes might be asserting. It did so because it had dismissed the federal claims over which it had original jurisdiction.
Leave to Amend and Disposition
The court granted Stokes 30 days to file an amended complaint alleging facts that could show a violation of the FMLA and complying with Rule 8. The order states that if he does not file an amended complaint within that period, the Clerk of Court will be directed to enter judgment in the action.
The court dismissed the complaint for failure to state a claim, granted leave to replead, and directed the Clerk to keep the matter open until a civil judgment is entered. Judge Kimba M. Wood also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.