Saidin v. The City of New York

Background

Mohammad Ariff Saidin, proceeding without a lawyer, sued the City of New York; Jeffrey Samuel & Partners, identified in the complaint as the law office for the City of New York; Adult Protective Services (APS); and eight APS employees. He also referred to unidentified John Doe defendants. He invoked federal-question jurisdiction and alleged violations involving protected opinion, due process, equal protection, contract, fraud, negligence, and discrimination based on mental and medical disability.

Saidin alleged that, beginning in summer 2017, APS replaced the Social Security Administration as the representative payee receiving his Supplemental Security Income benefits. He claimed that APS paid rent increases to his landlord despite poor apartment conditions, failed to mail seven months of benefit checks in 2019 and certain tax documents, and failed to provide promised movers, cleaning assistance, and an oxygen tank. He also alleged that these events worsened his mental-health and medical conditions. He sought corrective measures and monetary damages.

Standards and representative-payee claims

Because the complaint was filed without prepaying filing fees, the court screened it under 28 U.S.C. § 1915(e)(2)(B). That statute requires dismissal of a complaint that is frivolous or malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also explained that it must dismiss a case when it lacks subject-matter jurisdiction. Although courts read complaints filed by people without lawyers generously, such complaints must still include enough facts to make a claim plausible.

The court held that Saidin’s allegations about APS’s handling of his benefits concerned the Social Security Act’s representative-payee program. That law provides administrative remedies for alleged misuse of benefits but does not create a private lawsuit by a beneficiary against a representative payee for mismanagement. The court stated that a beneficiary generally must first seek relief from the Social Security Administration and obtain the agency decision required for judicial review. Because Saidin did not allege that he had presented these claims to the Social Security Administration, received the required agency decision, or had circumstances excusing exhaustion, the court held that he had to pursue that administrative process before proceeding on these claims in court.

Claims under 42 U.S.C. § 1983

Section 1983 provides a cause of action when a person acting under state authority violates a right secured by the Constitution or federal law. The court ruled that APS and the New York City Human Resources Administration were not entities that Saidin could sue. It dismissed the claims against the City because he did not allege that a City policy, custom, or practice caused a constitutional violation.

The court dismissed the claims against the eight APS employees because Saidin did not allege facts showing their personal involvement in violating his rights. It also dismissed the claims against Jeffrey Samuel & Partners because the complaint did not allege facts showing that the private law office acted under state authority or took action attributable to the City for purposes of Section 1983 liability.

The court separately considered the alleged constitutional violations. It dismissed the due-process claim because, although public benefits can be protected property interests, Saidin did not allege that he was deprived of such an interest without an opportunity to be heard. It dismissed the equal-protection claim because he did not allege that defendants treated him differently from similarly situated people or acted against him because of membership in a protected class.

Disability-discrimination claims

The court construed Saidin’s reference to discrimination based on mental and medical disability as potentially asserting claims under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. It dismissed those claims because he did not provide facts about his disability, a failure to reasonably accommodate it, or denial of access to services because of it. The court stated that even assuming he had a qualifying disability, the complaint did not allege the other facts required for relief under either statute.

State-law claims and leave to amend

Saidin’s contract, fraud, and negligence claims arose under state law. After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, which is a federal court’s discretionary authority to hear related state-law claims. The court also declined to grant leave to amend because it found that the defects in the complaint could not be cured by amendment.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii), without prejudice to Saidin’s pursuit of relief from the Social Security Administration and return to court after exhausting those remedies. The order states that all other matters were terminated.