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 claims were brought 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.

The court previously ordered Norris either to amend the complaint or explain why the case should not be dismissed for failing to adequately allege standing. Norris filed an amended complaint on November 7, 2025.

Court’s Analysis

The amended complaint did not state when Norris was allegedly denied access, including an approximate date, or describe the circumstances of the alleged denial beyond saying that it occurred before the lawsuit was filed. The court cited a Second Circuit decision holding that conclusory, boilerplate allegations about injury from a failure to accommodate visually impaired plaintiffs did not establish standing. The court stated that Norris’s allegations likely failed to adequately allege standing because they were at least as conclusory as the allegations in that earlier case.

Order and Effect

Judge Valerie Caproni did not dismiss the case in this order. Instead, the court ordered Norris, by no later than Friday, November 21, 2025, to file either a motion for leave to file another amended complaint that adequately alleges standing or a showing of why the case should not be dismissed for lack of standing. The required motion must include a memorandum of law and any supporting exhibits or declarations.