Taylor v. Childrens Village

Background

Tara Rashay Patrick Taylor filed this self-represented employment-discrimination action against Children’s Village, Jeremy C. Kohomban, Peter Friedman, Shaleigh Broughton, and Channette Wright. She invoked the Americans with Disabilities Act and Title VII of the Civil Rights Act of 1964, alleging that her employer discriminated against her because of a disability. Because she named individual defendants, the court also interpreted the complaint as potentially asserting claims under the New York State Human Rights Law.

Taylor alleged that Children’s Village knew about an illness that could cause unconsciousness while sitting still and knew that she had sought accommodations because of anemia. She also alleged that certain people knew she left a workplace location because of bullying, that requests to be reassigned were denied, and that Children’s Village refused to provide an internship, a promotion, and clinical supervision required to become a licensed mental health counselor in New York. She sought rehiring, clinical supervision, and money damages. The opinion states that the complaint appeared incomplete and that an employment-termination letter described by Taylor was not attached.

Taylor later submitted an email and a letter referring to the ADA, the Civil Rights Act, past mental and physical illnesses, video footage and documents, stalking, trafficking, domestic violence, and threats to her and her family. The opinion says it was unclear how those allegations related to the employment-discrimination claims.

Screening standard

Because Taylor had been permitted to proceed without paying the filing fee, the court was required to dismiss any claim that was frivolous, malicious, failed to state a claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that self-represented pleadings are read liberally, but still must provide enough factual detail to make a claim plausible under the federal pleading rules.

Motion to seal

The court treated Taylor’s January 5, 2021 letter as a request to seal the case materials. It explained that court records generally carry a strong presumption of public access and that the party seeking sealing must show sufficient reasons to overcome that presumption.

The court concluded that Taylor had not alleged enough facts to outweigh the public-access presumption. Her references to trafficking, stalking, and possible threats did not describe the nature of those risks or connect them to the employment-discrimination claims. The court therefore did not order the materials sealed. Instead, it directed the Clerk of Court to designate the complaint and the January 5 letter as “case-participant view only.” It stated that Taylor could request sealing of future filings, including an amended complaint, when submitting those filings.

Discrimination claims

The court held that the complaint did not state a claim under the Americans with Disabilities Act. Taylor referred to an illness that could cause unconsciousness and to anemia, but she did not provide enough facts showing a physical or mental impairment that substantially limited a major life activity, a record of such an impairment, or facts supporting the other disability theory recognized by the statute. The court also found that her letter did not adequately describe her past illnesses or the footage and documents allegedly used as the basis for discrimination.

More generally, Taylor did not explain what happened during her employment, what accommodation she requested, what reasons were given for her termination, or why she believed the termination was based on a disability or a record of a disability.

The court also held that Taylor did not state a Title VII claim. She did not identify her race, color, religion, sex, or national origin, and she did not allege facts suggesting that Children’s Village acted against her because of one of those characteristics.

The court granted Taylor leave to amend the complaint to allege facts supporting claims under the ADA and Title VII. It also stated that the individual defendants could not be held personally liable under those federal employment-discrimination statutes. The court said Taylor might be able to assert New York State Human Rights Law claims against the individual defendants under an aiding-and-abetting theory, but she had not explained how those defendants participated in unlawful discrimination. The court granted leave to allege facts showing such participation.

Leave to amend and disposition

The court granted Taylor leave to file an amended complaint within 60 days. The amended complaint had to state the relevant facts for each claim against each defendant, identify relevant people and their titles, describe what each defendant did or failed to do, provide dates and locations when possible, explain how the conduct violated Taylor’s rights, describe her injuries, and identify the relief sought. The amended complaint would replace the original complaint rather than add to it, so any claims or facts Taylor wanted to preserve had to be included again.

The court directed Taylor to submit the filing to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 20-CV-10997 (LLS). It stated that no summons would issue at that time and that, if Taylor did not amend within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also directed service of the order and the case-participant-only designation of the specified filings.