Applewhite v. N.Y.C. Dep't of Educ.

CourtCourt of Appeals for the Second Circuit
DecidedMarch 12, 2025
Docket24-2131
StatusUnpublished

This text of Applewhite v. N.Y.C. Dep't of Educ. (Applewhite v. N.Y.C. Dep't of Educ.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Applewhite v. N.Y.C. Dep't of Educ., (2d Cir. 2025).

Opinion

24-2131-cv Applewhite, et al. v. N.Y.C. Dep’t of Educ., et al.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 12th day of March, two thousand twenty-five.

PRESENT: DENNIS JACOBS, DENNY CHIN, SARAH A. L. MERRIAM, Circuit Judges.

__________________________________________

CARMEN APPLEWHITE; JAMILLAH SALAHUDDIN,

Plaintiffs-Appellants,

v. 24-2131-cv

NEW YORK CITY DEPARTMENT OF EDUCATION; RICHARD A. CARRANZA, Former Chancellor of NYC DOE; KRISTINA BEECHER, Principal of P.S. 3 Within District 13; THOMAS MCBRYDE, Superintendent of District 19; RONALD JAMES, JR., Principal of P.S. 202 in District 19; TIFFANY RICHARDS, Assistant Principal of P.S. 202 in District 19; CITY OF NEW YORK,

Defendants-Appellees. * __________________________________________

FOR PLAINTIFFS-APPELLANTS: CARMEN APPLEWHITE, and JAMILLAH SALAHUDDIN, pro se, Brooklyn, NY.

FOR DEFENDANTS-APPELLEES: GEOFFREY E. CURFMAN (Ingrid R. Gustafson, on the brief), of counsel, for Muriel Goode-Trufant, Corporation Counsel of the City of New York, New York, NY.

Appeal from a judgment of the United States District Court for the Eastern District

of New York (Ann M. Donnelly, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment entered on August 9, 2024, is AFFIRMED.

Carmen Applewhite and Jamillah Salahuddin brought this action against the New

York City Department of Education (“NYC DOE”), several NYC DOE employees, and the

City of New York. They asserted federal claims arising under the Whistleblower Protection

Act (“WPA”), the National Labor Relations Act (“NLRA”), Title VII, the Americans with

Disabilities Act (“ADA”), the Rehabilitation Act, and the First Amendment related to their

treatment while employed at the NYC DOE. They also asserted state law violations and

attempted to bring disability discrimination claims on behalf of their special education

* The Clerk’s Office is directed to amend the caption as reflected above.

2 students. The District Court dismissed all of their claims. See Applewhite v. N.Y.C. Dep’t

of Educ., No. 1:21CV02928(AMD), 2024 WL 3718675 (E.D.N.Y. Aug. 8, 2024).

We assume the parties’ familiarity with the remaining facts, the procedural history,

and the issues on appeal.

I. Abandonment of Arguments on Appeal

Plaintiffs’ brief on appeal gives only cursory treatment to several issues, addressing

them in only one or two sentences. Issues not sufficiently argued in briefs, even by self-

represented parties, are considered abandoned and normally will not be addressed by this

Court. See Gerstenbluth v. Credit Suisse Sec. (USA) LLC, 728 F.3d 139, 142 n.4 (2d Cir.

2013). As such, we consider here only those arguments that plaintiffs have raised in more

than a cursory manner: (1) that they had standing to sue on behalf of their students, (2) that

Salahuddin stated a plausible First Amendment retaliation claim, and (3) that their ADA

failure to accommodate claims were improperly dismissed.

II. Plaintiffs’ Claims Regarding Alleged Harm to Students

This Court “review[s] de novo the District Court’s decision to dismiss [a] complaint

for lack of standing . . . , construing the complaint in plaintiffs’ favor and accepting as true

all material factual allegations.” Dubuisson v. Stonebridge Life Ins. Co., 887 F.3d 567, 573

(2d Cir. 2018) (quotation marks, citation, and alterations omitted). The SAC makes a

number of allegations of harm to plaintiffs’ students, including: Salahuddin’s students were

denied an “age appropriate bathroom”; the allegedly hostile work environment created an

“unsafe learning environment” for Applewhite’s students; and the NYC DOE “knowingly

denied students with special needs mandated services” and “discriminated against them.”

3 Second Amended Complaint (“SAC”), Applewhite, No. 1:21CV02928(AMD) (E.D.N.Y.

Oct. 16, 2023), ECF No. 70 at 14, 11, 24. It is unclear whether plaintiffs seek relief on

behalf of their students or on their own behalf for these alleged harms – or if these

allegations are mere context.

To the extent they seek to vindicate their students’ rights, plaintiffs – who are not

lawyers – cannot represent their students in federal court. The law “does not permit

unlicensed laymen to represent anyone else other than themselves.” Lattanzio v. COMTA,

481 F.3d 137, 139 (2d Cir. 2007) (per curiam) (quotation marks and citation omitted). To

the extent these allegations are intended to reflect claims for associational discrimination,

the SAC fails to allege any injury to plaintiffs causally linked to discrimination against their

students. “[T]o gain entry to the courts, non-disabled parties bringing associational

discrimination claims need only prove an independent injury causally related to the denial

of federally required services to the disabled persons with whom the non-disabled plaintiffs

are associated.” Loeffler v. Staten Island Univ. Hosp., 582 F.3d 268, 279 (2d Cir. 2009)

(Wesley, J., concurring). 1

Accordingly, any claims in the SAC based on alleged harm to plaintiffs’ students

are properly dismissed for failure to state a claim or for lack of standing.

III. Merits of Plaintiffs’ Claims

This Court reviews de novo a district court’s dismissal of a complaint for failure to

state a claim, construing submissions by self-represented parties liberally, accepting all

1 Judge Wesley’s concurrence represented the panel’s majority opinion on this issue. See Loeffler, 582 F.3d at 270.

4 factual allegations in the complaint as true, and drawing all reasonable inferences in the

plaintiffs’ favor. See Harris v. Mills, 572 F.3d 66, 71–72 (2d Cir. 2009).

A. First Amendment Retaliation Claim

The only alleged instance of First Amendment retaliation mentioned by plaintiffs in

their brief is the claim that Salahuddin “was taken off email lists pertinent to her job and

her access to her schools.nyc.gov. was terminated” after “raising the alarm about what was

happening to the special education students.” Appellants’ Br. at 6. This allegation does

not state a First Amendment retaliation claim.

A public employee making a First Amendment retaliation claim under 42 U.S.C.

§1983 “must show that (1) her speech was constitutionally protected, (2) she suffered from

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Related

Lattanzio v. Comta
481 F.3d 137 (Second Circuit, 2007)
Gerstenbluth v. Credit Suisse Securities (USA) LLC
728 F.3d 139 (Second Circuit, 2013)
McBride v. BIC Consumer Products Manufacturing Co.
583 F.3d 92 (Second Circuit, 2009)
Loeffler v. Staten Island University Hospital
582 F.3d 268 (Second Circuit, 2009)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Phillips v. Bowen
278 F.3d 103 (Second Circuit, 2002)
Dubuisson v. Stonebridge Life Ins. Co.
887 F.3d 567 (Second Circuit, 2018)

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