Williams v. Urban Pathways Inc.

Background

Dwight Andre Williams, representing himself, sued Urban Pathways Inc., which the opinion describes as a social service organization located in New York City. Williams was formerly a resident of the Ivan Shapiro House, a residence operated by Urban Pathways. He alleged that staff members and other residents mistreated him between September 18, 2019, and November 21, 2019, and that Urban Pathways discharged him from its program because he is Black. He sought money damages.

The complaint also described alleged threats by a maintenance director, alleged racial slurs by residents, an alleged knife incident involving a maintenance worker, and Urban Pathways staff’s alleged failure to respond to reports about narcotics sales and threats. The opinion does not decide these allegations on their merits.

Screening standard

Because Williams had been allowed to proceed without paying filing fees in advance, the court was required to screen his complaint. Under 28 U.S.C. § 1915(e)(2)(B), the court said it had to dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. The court also noted that it must dismiss a case when it lacks subject-matter jurisdiction. Although courts read filings by people without lawyers generously, the complaint still must provide enough factual detail to make a claim legally plausible.

Court’s analysis

The court interpreted Williams’s housing-discrimination allegations as claims under the Fair Housing Act, which prohibits discrimination in housing based on characteristics including race, color, religion, sex, familial status, national origin, and disability. The law also prohibits retaliation for asserting rights protected by the Act.

Williams alleged that a director ended his tenancy while not ending the tenancy of a white female resident. The court held that this comparison, without supporting facts, did not create a reasonable inference that Urban Pathways terminated Williams because of his race. The court stated that Williams asserted the director considered his race but did not provide facts supporting that conclusion. It therefore held that Williams failed to state a Fair Housing Act claim against Urban Pathways.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(11), as stated in the order, and granted Williams 30 days’ leave to amend. The order did not state that the dismissal was with prejudice or without prejudice. Judge Louis L. Stanton said amendment was allowed because it was not clear that the complaint’s defects could not be corrected by adding facts supporting the claim that Urban Pathways terminated Williams’s residency because of his race.