Norris v. 684 Pizza

Background

Namel Norris sued 684 Pizza, Inc., doing business as West Side Pie, and Enterprise 51 Parking LLC. Norris alleged that the defendants denied full and equal access to and enjoyment of facilities at their property. The complaint asserted claims under the Americans with Disabilities Act, the New York State Human Rights Law, the New York City Human Rights Law, and the New York City Administrative Code.

Standing issue

The court addressed standing, which is the requirement that a plaintiff show a real injury connected to the defendants’ conduct and likely to be remedied by a court decision. For a plaintiff seeking an order requiring access under the Americans with Disabilities Act, the complaint must allege a past violation, a reasonable basis to believe the discrimination will continue, and a reasonable basis to believe the plaintiff intends to return to the location.

The court noted that the Second Circuit has rejected conclusory, boilerplate allegations as insufficient to establish standing. The court said the allegations in Norris’s complaint likely failed for the same reason and were at least as conclusory as the allegations previously rejected by the Second Circuit.

Order

The court ordered Norris to file an amended complaint that adequately alleges standing no later than November 21, 2025. Alternatively, Norris must show cause—explain why—the case should not be dismissed for lack of standing. The order did not itself dismiss the case, decide the underlying disability-access claims, or rule on the defendants’ liability.