Tanner v. MTA Long Island Railroad

Background

Walter Tanner filed an amended complaint after the court’s January 17, 2023 order dismissed his original action but allowed him to replead certain claims. Tanner sued MTA Long Island Railroad, doing business as the Metropolitan Transportation Authority, and Lisa Martinez, Willie Jenkins, Kevin McCaffrey, and Kathleen Meilick. The opinion identifies Martinez, Jenkins, McCaffrey, and Meilick as LIRR personnel or former personnel. Tanner alleged that harassment at his former LIRR workplace ultimately led to termination of his employment on or about May 22, 2015.

Tanner also asked the federal court to take over or review an associated New York state-court case. He alleged that the state appellate court denied him due process when he tried to challenge events involving his retained lawyer and the state court’s decision. He sought reinstatement, damages, backpay, pension-related credit and vesting, restoration of time-off benefits, removal of negative materials from his personnel file, and other relief.

Rooker-Feldman jurisdiction ruling

The court dismissed any claims challenging the New York Supreme Court’s grant of summary judgment in Tanner’s state-court labor and employment case and the Appellate Division’s dismissal of his appeal. It held that the federal court lacked subject-matter jurisdiction over those challenges under the Rooker-Feldman doctrine, which prevents a federal district court from functioning as an appeal court for final state-court judgments. The court also treated Tanner’s requests to “carry over” the state case as subject to that jurisdictional ruling.

Title VII claims

The court dismissed Tanner’s Title VII claims against the individual defendants for failure to state a claim because Title VII does not provide for claims against individual employees. Although Tanner named LIRR as his former employer, the court also dismissed his Title VII claims against LIRR. Tanner did not allege facts showing that race, color, sex, religion, or national origin was a motivating factor in an adverse employment action.

Claims under 42 U.S.C. § 1983

The court dismissed Tanner’s Section 1983 claims arising from the alleged workplace events, termination, and his detention and removal from an LIRR office building by police. The court had previously determined that the claims appeared to be filed after the applicable three-year limitations period. In the amended complaint, Tanner did not allege facts showing that the claims were timely or that the filing period should be extended under equitable tolling, a doctrine that can sometimes excuse an otherwise late filing.

State-law claims and other rulings

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims. Supplemental jurisdiction is the federal court’s authority to hear related state-law claims in the same case; the court explained that it generally declines that authority when the federal claims have been dismissed at an early stage.

The court dismissed the action. It denied Tanner’s pending request for the court to seek volunteer counsel as moot. It also certified that an appeal would not be taken in good faith and denied Tanner permission to proceed without paying filing fees for purposes of an appeal. The clerk was directed to enter judgment.