Williams v. New York City Department Of Correction

Background

Daniel Williams sued the New York City Department of Correction, the City of New York, and John Does 1–10. He alleged unlawful race discrimination and retaliation under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. The opinion states that Williams had been terminated from the New York City Department of Correction.

The court had previously dismissed Williams’s original complaint for failing to plausibly state a claim but allowed him to amend. The amended complaint largely repeated the original allegations and added two facts: an investigator allegedly told Williams that investigations were “slaying people that look like me and you and giving everybody else a pass,” and Williams alleged, “upon information and belief,” that all non-African-American probationary officers present during a March 2017 incident had similar evaluations, disciplinary histories, and conduct.

Legal standard

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not allege enough facts to make relief plausible. The court accepted factual allegations as true for purposes of the motion but did not accept legal conclusions or unsupported statements.

Discrimination claims

The court held that the investigator’s statement did not by itself plausibly support a race-discrimination claim. Williams did not provide information about the investigator’s ethnicity or explain whether the investigator’s reference to people who “look like me and you” referred to African Americans. He also did not explain how the investigations unit was connected to his termination or what role it played in the alleged investigations and departmental charges.

The court further reasoned that, even with additional clarification, the statement appeared to describe the investigator’s perception of how others made termination decisions rather than show that the investigator made those decisions. The statement therefore could not, standing alone, establish facts suggesting discriminatory motivation.

The court separately rejected Williams’s disparate-treatment theory. To support that theory, Williams needed to plausibly allege that he was treated less favorably than a similarly situated employee outside his protected group. The court held that his allegation about the other probationary officers was conclusory because he provided no facts about their conduct, evaluations, or disciplinary histories and no facts supporting his asserted belief. The court dismissed the disparate-treatment claim.

Other federal claims

The court dismissed Williams’s remaining federal claims for retaliation, hostile work environment, and Fourteenth Amendment violations because the amended complaint added no new factual allegations concerning those claims. The court also dismissed Williams’s First and Thirteenth Amendment claims because he appeared no longer to pursue them.

State and local claims

Williams also asserted discrimination and retaliation claims under state and local law. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction, meaning it declined to decide the related state and municipal claims in this federal case. The court stated that doing so would not harm judicial economy, convenience, or fairness because the federal claims had been addressed and dismissed early in the litigation.

Disposition

The court granted the defendants’ motion to dismiss, directed the clerk to terminate the motion at docket entry 21, and ordered the case closed. The opinion does not state whether the dismissal was with or without prejudice.