Salahuddin v. Donnellan Gambella

Background

Shaifah Salahuddin, proceeding without a lawyer, sued Ariana Donnellan Gambella, Richard E. Casagrande, Jeffery H. Gamils, Laura Hemans Brantley, and John Paul Guyette. She asserted claims under the Americans with Disabilities Act, the Rehabilitation Act, the Age Discrimination in Employment Act, Title VII of the Civil Rights Act, and state law.

The claims arose from Salahuddin’s employment with the New York City Department of Education, a 2013 settlement agreement ending a disciplinary proceeding, and her earlier federal lawsuit concerning alleged blacklisting from employment with DOE vendors. Salahuddin alleged that attorneys involved in the disciplinary proceeding deceived or pressured her into signing the settlement agreement and that Guyette continued the alleged misconduct while representing DOE in the earlier lawsuit. She sought damages, injunctions, and declarations.

Claims Against Gamils, Brantley, and Guyette

The court applied claim preclusion, also called res judicata. Claim preclusion prevents a party from bringing a later case based on the same claims or events when an earlier case ended with a merits judgment involving the same party or someone legally connected to that party.

The court held that all requirements were met for the claims against Gamils, Brantley, and Guyette. It treated the earlier dismissal for failure to state a claim, and the denial of leave to file a second amended complaint, as an adjudication on the merits. It also held that these defendants were legally connected to DOE because they were DOE’s attorneys, and that Salahuddin’s claims arose from the same events involved in the earlier lawsuit. The court therefore dismissed all of Salahuddin’s claims against Gamils, Brantley, and Guyette for failure to state a claim under the statute governing dismissal of fee-free cases.

The court noted that some allegations against Guyette appeared to concern his conduct while representing DOE in the earlier lawsuit. It stated that those allegations did not state a legally recognized federal claim.

Federal Claims Against the Other Defendants

The court alternatively dismissed Salahuddin’s claims under the Americans with Disabilities Act, the Rehabilitation Act, the Age Discrimination in Employment Act, and Title VII against all defendants because those statutes do not impose liability on individual defendants. The court used the failure-to-state-a-claim ground for that ruling.

State-Law Claims and Leave to Amend

The court treated the remaining claims against Donnellan Gambella and Casagrande, and possibly some claims against Guyette, as state-law claims. After dismissing the claims within its original federal jurisdiction, the court declined to exercise supplemental jurisdiction over those remaining state-law claims. The court also declined to give Salahuddin permission to amend because it found that the defects could not be cured by amendment.

Disposition and Warning

The court dismissed the action. Specifically, it dismissed all claims against Gamils, Brantley, and Guyette, and dismissed the federal claims against Donnellan Gambella and Casagrande, for failure to state a claim. It declined to consider the remaining state-law claims against Donnellan Gambella and Casagrande, and any state-law claims against Guyette that had not already been dismissed, under supplemental jurisdiction.

The court warned that further duplicative or frivolous litigation concerning the 2013 settlement agreement or alleged DOE-vendor blacklisting could lead to an order barring Salahuddin from filing a new civil action in that court without paying fees unless she first obtained the court’s permission. The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.