Williams v. Dudley
- John Cronan
- 1:23-cv-11018
- U.S. District Court · Southern District of New York
- 3
In Williams v. Dudley, Judge Cronan added HRA as a defendant and ordered summonses, allowing service within ninety days.
Isaac Jay Williams, New York City Human Resources Administration, Jacqueline Dudley, and Samuel Salnave.
What happened
In Williams v. Dudley, Isaac Jay Williams, who is representing himself, sued Jacqueline Dudley and Samuel Salnave under disability-discrimination laws, alleging discrimination at his workplace, the New York City Human Resources Administration (HRA).
The court added HRA as a defendant because the Americans with Disabilities Act claims could not be brought against the individual defendants in their personal capacities. It ordered summonses for HRA, Dudley, and Salnave and gave Williams ninety days after the summonses are issued to serve them or request more time.
Judge John P. Cronan issued this order on February 2, 2024. The order addressed adding a defendant and beginning service; it did not decide whether Williams’s claims are legally or factually valid.
The detailed version
- Williams v. Dudley · No. 1:23-cv-11018
- John Cronan
- Feb. 2, 2024
Background
Isaac Jay Williams, proceeding without a lawyer, brought claims under the Americans with Disabilities Act of 1990, the New York State Human Rights Law, and the New York City Human Rights Law. He alleged that disability discrimination occurred at his workplace, the New York City Human Resources Administration (HRA). His complaint named Jacqueline Dudley and Samuel Salnave as defendants.
Adding HRA as a Defendant
The court stated that Americans with Disabilities Act claims cannot be brought against individual defendants in their personal capacities. Because Williams appeared to intend to bring those claims against his employer, and because he was proceeding without a lawyer, the court directed the Clerk of Court under Federal Rule of Civil Procedure 21 to add HRA as a defendant.
Summonses and Service
The court directed the Clerk of Court to issue summonses for HRA, Dudley, and Salnave. Williams must serve each defendant with the summons and complaint within ninety days after the summonses are issued, or request an extension of time. The court stated that it may dismiss the claims under Rules 4 and 41 for failure to prosecute if Williams does neither within that period. The court extended the service period from the usual ninety days after filing because summonses were not issued when Williams filed the complaint while he had not yet paid the filing fee.
Disposition
The court ordered the Clerk of Court to add HRA as a defendant and issue summonses for all three defendants. It also provided information about optional electronic service and directed the Clerk to mail Williams an information package. This order did not decide the merits of the alleged discrimination or any other claim.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.