Jones v. Association for Rehabilitative Case Management and Supported Housing…

Background

Hope Jones alleged that the Association for Rehabilitative Case Management and Supported Housing Program, Inc. (ACMH) discriminated against her because of her mental and physical disabilities. The claims invoked the Fair Housing Act, the Americans with Disabilities Act, the New York State Human Rights Law, the New York City Human Rights Law, New York State Office of Mental Health regulations, and contracts between ACMH and city agencies. Jones sought declaratory and injunctive relief, damages, attorney’s fees, and costs.

Jones lived in a housing facility operated through ACMH’s Supported Apartments Program, which serves adults diagnosed with serious mental illness. ACMH leased apartments from building landlords and subleased them to participants in its housing program. ACMH operated the program under a contract with the New York State Office of Mental Health and received funding from that office and the New York City Department of Health and Mental Hygiene.

In June 2018, ACMH started a Bronx Housing Court proceeding against Jones for nonpayment of rent. Jones later asked that court to dismiss the proceeding, or alternatively to let her amend her answer and conduct discovery. The Housing Court denied dismissal and discovery, allowed her to amend her answer, and struck several defenses, including a reasonable-accommodation defense based on its determination that it lacked authority to consider that issue. The Housing Court later denied Jones’s request to reargue. No judgment was entered against Jones in the May 2019 order.

Jones then requested reasonable accommodations from ACMH, including ending the nonpayment proceeding, helping her apply for rental assistance, and repairing conditions in her apartment. She filed this federal action in October 2019, alleging disability discrimination and denial of an equal opportunity to use and enjoy her housing.

Motion and Legal Standard

ACMH moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), arguing that the federal court lacked subject-matter jurisdiction. Subject-matter jurisdiction is a court’s legal authority to hear a type of case. At the pleading stage, the court generally accepts the complaint’s material factual allegations as true and draws reasonable inferences for the plaintiff, although it may also consider evidence outside the pleadings when deciding a Rule 12(b)(1) motion.

Rooker-Feldman Analysis

ACMH argued that the Rooker-Feldman doctrine barred the action. That doctrine generally prevents a federal district court from acting as an appeals court over a state-court judgment. The court explained that the doctrine applies only when four conditions are met: the federal plaintiff lost in state court, the claimed injury was caused by the state-court judgment, the federal claims ask the district court to review and reject that judgment, and the state judgment came before the federal case.

The court held that the first condition was not met. The Housing Court had not entered a judgment against Jones on her discrimination claims. Instead, it had determined that it lacked authority to adjudicate those claims in the summary housing proceeding, declined to dismiss the proceeding, and refused to allow Jones to add those issues as affirmative defenses. The federal court therefore concluded that Jones’s alleged injury—disability discrimination under federal law—had not been decided by a state-court judgment that the federal court was being asked to review.

Disposition

The court held that it had subject-matter jurisdiction under federal-question and civil-rights jurisdiction statutes, and supplemental jurisdiction over Jones’s related state-law claims. Judge Colleen McMahon denied ACMH’s motion to dismiss for lack of subject-matter jurisdiction and directed the Clerk of Court to close the motion. The opinion resolved jurisdiction only; it did not rule on the ultimate merits of Jones’s discrimination claims.