Williams v. New York City Department of Education

Background

Deonca Williams brought the action without a lawyer 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. She alleged that her former employer, the New York City Department of Education, and Assistant Principal Felicia Bray discriminated against her based on national origin. Williams alleged that Bray and others made intentionally false statements, forged her signature on evaluations, interfered with appeals concerning her discontinuance, made false claims to a state unemployment agency, and placed a problem code on her personnel or Galaxy account. She alleged that the code permanently prevented her from working within any division of the Department or for its third-party vendors. She sought removal of the code and compensation for lost salary and benefits. She attached an October 13, 2020 notice of right to sue from the Equal Employment Opportunity Commission as evidence that she had exhausted administrative remedies.

Court’s analysis

Because Williams had been allowed to proceed without paying the filing fee, the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B). That statute requires dismissal of an appropriate portion of a complaint that is frivolous, malicious, fails to state a claim, or seeks money from an immune defendant. The court also noted that it must dismiss a complaint when it lacks subject-matter jurisdiction. Although courts read complaints filed by people without lawyers liberally, those complaints must still provide enough factual detail to make the claimed violation plausible.

The court explained that a Title VII employment-discrimination claim requires facts plausibly showing both an adverse employment action and that a protected characteristic—such as national origin—was a motivating factor in the employment decision. The court held that Williams’s allegations were insufficient because she did not allege facts suggesting that the employer took an adverse employment action against her because of a protected characteristic. The opinion’s express merits analysis addresses the Title VII claims; it does not separately analyze the New York State or New York City claims.

Disposition

The court granted Williams leave to file an amended complaint within sixty days. The amended complaint had to provide a short and plain statement of the relevant facts, identify the people involved and their titles, describe each defendant’s conduct or failure to act, give approximate dates and locations, describe Williams’s injuries, and state the requested relief. Any facts or claims from the original complaint that Williams wanted the court to consider had to be repeated because the amended complaint would replace, rather than supplement, the original complaint.

The court directed Williams to submit the amended complaint to the Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 21-CV-0520 (LTS). No summons would issue at that time. If Williams did not comply within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied Williams permission to proceed without paying fees for an appeal from this order.