Hill v. Maffucci Moving and Storage
- Lorna Schofield
- 1:21-cv-08746
- U.S. District Court · Southern District of New York
- 3
In Hill v. Maffucci Moving and Storage, Judge Schofield dismissed the claims because neither federal-question nor diversity jurisdiction existed.
The pro se plaintiffs’ ADA and New York City Human Rights Law claims were dismissed, and the case was closed; the opinion does not identify the individual defendants beyond the caption.
What happened
In Hill v. Maffucci Moving and Storage, the pro se plaintiffs sued under the Americans with Disabilities Act and New York City Human Rights Law. They based the federal claim on an earlier state-court case and alleged that traveling to Suffolk County for proceedings was disability discrimination.
The court said those allegations did not present a valid federal claim. It also found no diversity jurisdiction because the plaintiffs and Maffucci Moving and Storage were all connected to New York for jurisdictional purposes. The plaintiffs did not file the letter the court had ordered addressing these problems.
Judge Lorna G. Schofield dismissed the plaintiffs’ claims for lack of subject-matter jurisdiction and directed the Clerk of Court to serve the order and close the case.
The detailed version
- Hill v. Maffucci Moving and Storage · No. 1:21-cv-08746
- Lorna Schofield
- Jan. 4, 2022
Background
On October 26, 2021, Ann V. Hill and the other plaintiffs filed the complaint without lawyers. They invoked federal-question jurisdiction and diversity jurisdiction and asserted claims under the Americans with Disabilities Act (ADA) and the New York City Human Rights Law (NYCHRL).
The ADA claim was based on an earlier case the plaintiffs had filed in Suffolk County state court. The plaintiffs alleged that the defendants defaulted in that proceeding and that the plaintiffs’ resulting travel to Suffolk County for court proceedings amounted to disability discrimination under the ADA.
Jurisdictional Analysis
The court explained that federal courts must independently determine whether they have subject-matter jurisdiction, meaning legal authority to hear the case. It found that the complaint did not state a colorable federal claim. The court concluded that the allegations about the state-court proceeding and travel to Suffolk County did not create federal-question jurisdiction.
The court also found that diversity jurisdiction was unavailable. Diversity jurisdiction requires complete diversity, meaning that every plaintiff must be a citizen of a different state from every defendant, and generally requires more than $75,000 to be at issue. The opinion states that the plaintiffs were New York citizens and that Maffucci Moving and Storage was headquartered in New York. Therefore, complete diversity was absent.
On December 2, 2021, the court directed the plaintiffs to file a letter explaining any legal basis for subject-matter jurisdiction and any reason the case should not be dismissed. No letter was filed.
Disposition
The court ordered that the plaintiffs’ claims were dismissed for lack of subject-matter jurisdiction. It directed the Clerk of Court to serve the order on the pro se plaintiffs and close the case. This was a jurisdictional dismissal rather than a decision on whether the alleged ADA or NYCHRL violations occurred.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.