Warren v. 111 Tenants Corp.

Background

Harold Warren, a self-represented plaintiff, sued 111 Tenants Corporation. The court liberally construed his complaint as asserting claims for discrimination and retaliation under the Fair Housing Act and 42 U.S.C. §§ 1981 and 1982; conspiracy under 42 U.S.C. § 1985; related claims under 42 U.S.C. § 1986; and claims under state, city, and common law.

Timeliness Issue

The complaint indicated that the challenged conduct occurred in the 1980s and that Warren knew about the alleged discrimination when it occurred. The court explained that the federal claims had limitation periods ranging from one to four years. It therefore concluded that the limitation period for each federal claim appeared to have expired decades earlier.

The court ordered Warren to show cause—explain why the claims should not be dismissed—as to why his federal claims should not be dismissed as untimely. Warren did not respond by the original deadline. The court then granted him an extension on its own initiative, again warning that failure to respond would result in dismissal of the federal claims as untimely and declining to use supplemental jurisdiction over the state-law claims. Warren still did not respond.

Ruling

The court dismissed Warren’s federal claims as untimely. It declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over Warren’s state-law claims. The Clerk of Court was directed to close the case. Judge Arun Subramanian issued the order on January 4, 2024.