Miles v. New York-Presbyterian Hospital

Background

Dylan Miles, who was proceeding without a lawyer, sued New York Presbyterian Hospital, Magali Lopez, and Doctors Asad Sidddiqi, Mike Mizrahi, and Daniel Jung Pak. The complaint invoked federal-question jurisdiction and asserted a claim under Title VII of the Civil Rights Act, along with eight state-law causes of action.

Miles alleged that she received treatment at the hospital for chronic pain conditions. She said that she was told to find a new pain-management doctor, that medication options were discussed, and that an alternative medication was unaffordable because her insurance would not cover it. She alleged that Dr. Mizrahi said he could not help her, that Lopez removed her from the practice, and that Dr. Pak said he would prescribe Naloxone but did not do so. Miles also alleged that Doctors Siddiqi, Mizrahi, and Pak made insulting comments about her gender identity, mocked her condition, and tried to prevent her from obtaining medication.

Title VII claim

The court explained that Title VII prohibits employers from discriminating against employees because of protected characteristics, including sex. Although Miles alleged discrimination based on sex and gender identity, the court found that she did not allege that she had an employment relationship with New York Presbyterian Hospital or any individual defendant. She also did not allege discrimination involving employment compensation, terms, conditions, or privileges.

The court therefore dismissed the Title VII claim for failure to state a claim on which relief could be granted. The court concluded that none of the defendants was Miles’s employer and that amending the complaint to replead a Title VII employment-discrimination claim would be futile.

State-law claims

After dismissing the only federal claim, the court declined to exercise supplemental jurisdiction over Miles’s state-law claims. Supplemental jurisdiction is the federal court’s authority to hear related state-law claims alongside federal claims. The court stated that nothing in the order prevented Miles from pursuing the state-law claims in state court.

Opportunity to amend and appeal status

In an abundance of caution, the court held the matter open on the docket for 30 days so Miles could file an amended complaint asserting another possible federal claim arising from the alleged discrimination. The order required any amended complaint to be submitted to the court’s Pro Se Intake Unit, labeled “Amended Complaint,” and include docket number 22-CV-3161 (LTS). The Clerk was directed not to enter judgment at that time, and no summons would issue.

Judge Laura Taylor Swain also certified that any appeal would not be taken in good faith and denied Miles permission to proceed without prepaying fees for purposes of an appeal.