Williams v. New York City Department Of Education
- Ronnie Abrams
- 1:18-cv-11621
- U.S. District Court · Southern District of New York
- 15
In Williams v. DOE, Judge Abrams granted the Department of Education’s motion to dismiss disability, medical-privacy, and related state-law claims, allowing amendment.
Meosha Y. Williams’s federal disability and HIPAA claims were dismissed; her state and city claims were not decided because the court declined supplemental jurisdiction. The defendants were granted the motion to dismiss, but Williams was allowed to amend her complaint.
What happened
In Williams v. New York City Department of Education, former teacher Meosha Y. Williams, representing herself, alleged disability discrimination and related misconduct by the Department and principal Rosie Sifuentes-Rosado. She relied on the Americans with Disabilities Act, the Health Insurance Portability and Accountability Act, and New York state and city laws.
The court ruled that the disability claims were not adequately pleaded because Williams did not identify a qualifying disability or explain how her medical problems substantially limited major life activities. The court also dismissed the medical-privacy claim as too late and declined to decide the state and city claims after dismissing the federal claims.
Judge Ronnie Abrams granted the defendants’ motion to dismiss but gave Williams until March 25, 2020, to file an amended complaint.
The detailed version
- Williams v. New York City Department Of Education · No. 1:18-cv-11621
- Ronnie Abrams
- Feb. 25, 2020
Background
Meosha Y. Williams, proceeding without a lawyer, sued the New York City Department of Education and Rosie Sifuentes-Rosado. Williams was a former DOE teacher assigned to PS/MS 194. She alleged that, from February through June 2013, the defendants discriminated against her because of an unspecified disability, harassed her, denied or interfered with medical leave, took employment actions against her, and forced her to resign. She also alleged that two faculty members went to her doctor’s office to verify her medical condition and treatment.
The court construed the pleadings as asserting claims under the Americans with Disabilities Act (ADA), the Health Insurance Portability and Accountability Act (HIPAA), the New York City Human Rights Law, and related state laws. The defendants moved to dismiss.
ADA claims against Sifuentes-Rosado
The court dismissed the ADA claims against Sifuentes-Rosado with prejudice. It held that the ADA does not provide for individual liability in employment-discrimination cases.
ADA claims against the DOE
The court dismissed the ADA claims against the DOE. To state an ADA claim, Williams had to plausibly allege, among other things, that she had a disability covered by the statute and that the DOE knew about it.
The court found that Williams did not identify her disability. Her references to “disabilities,” severe hypertension, flu-like symptoms, a panic attack, failing health, and medical leave did not explain how an impairment substantially limited one or more major life activities. The court also concluded that taking several short medical leaves and having a panic attack did not, by themselves, plausibly establish an ADA disability.
The court further held that Williams did not allege that the DOE knew she had a qualifying disability. The allegations that school personnel knew about her symptoms, medical limitations, or panic attack did not establish knowledge of a disabling condition. The court also noted that many of the alleged medical problems occurred after Williams had tendered her resignation, which made the required connection between a disability and an adverse employment action unlikely.
HIPAA claim
The court treated Williams’s opposition papers as asserting a HIPAA claim based on the alleged visit by faculty members to her doctor’s office. The court dismissed that claim because it was filed after the applicable three-year limitations period. The court also stated that, even if the claim had been timely, it would likely fail because HIPAA may not provide a private right to sue.
State and city claims
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over Williams’s New York state and municipal claims. Supplemental jurisdiction allows a federal court to hear related state-law claims, but the court generally may decline that jurisdiction after dismissing all federal claims. The court therefore did not decide whether Williams had stated a claim under state or city law.
Disposition
Judge Ronnie Abrams granted the defendants’ motion to dismiss. The court gave Williams an opportunity to amend her complaint and directed her to file any amended complaint by March 25, 2020. The opinion does not state a separate prejudice designation for the DOE’s ADA claims or the HIPAA claim.
Read the full 15-page opinion on CourtListener, the free public archive maintained by the Free Law Project.