Baez v. New York State Office of Temporary and Disability Assistance

CourtDistrict Court, S.D. New York
DecidedMarch 28, 2025
Docket1:24-cv-03282
StatusUnknown

This text of Baez v. New York State Office of Temporary and Disability Assistance (Baez v. New York State Office of Temporary and Disability Assistance) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baez v. New York State Office of Temporary and Disability Assistance, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK WANDA BAEZ, SIIDE GIL- FREDERICK, DANIELLE JOHNSON, and RESIDENTS TO PRESERVE PUBLIC HOUSING, Plaintiff, OPINION & ORDER – against – 24-cv-3282 (ER) NEW YORK STATE OFFICE OF TEMPORARY AND DISABILITY ASSISTANCE, and NEW YORK CITY HOUSING AUTHORITY, Defendants. RAMOS, UNITED STATES DISTRICT JUDGE: Wanda Baez, Siide Gil-Frederick, Danielle Johnson, and Residents to Preserve Public Housing (“RPPH”) (collectively, “Plaintiffs”) bring this putative class action against the New York State Office of Temporary and Disability Assistance (“OTDA”) and the New York City Housing Authority (“NYCHA”) (collectively, the “Defendants”). Plaintiffs allege that Barbara C. Guinn, in her individual capacity as OTDA commissioner, OTDA, and NYCHA discriminated against Black and Hispanic or Latino public subsidized housing tenants in violation of the Fair Housing Act (“FHA”), Title VI of the Civil Rights Act of 1964, and New York State Human Rights Laws. Doc. 40. Before the Court is the Defendants’ motions to dismiss the suit in its entirety. Docs. 51 and 55. For the reasons set forth below, the motion is GRANTED. I. BACKGROUND �e following facts are based on the allegations in the first amended complaint (“FAC”), which the Court accepts as true for the purposes of this instant motion.1 See Koch v. Christie’s International PLC, 699 F.3d 141, 145 (2d Cir. 2012). During the COVID-19 pandemic, Congress passed the Consolidated Appropriations Act, 2021, which provided eligible states with federal funding to implement the Emergency Rental Assistance Program (“ERAP”). Doc. 40. ¶¶ 7, 36. �is program was intended to help renters experiencing financial hardship due to the pandemic manage rental costs. Id. ¶ 9. Eligible renters would receive “up to twelve months of rental and/or utility assistance arrears and three months of prospective rental assistance.” Id. ¶ 48. Under the Consolidated Appropriations Act, the state of New York received federal funding to be used toward “rental arrears, utilities, home energy arrears, and other housing related expenses incurred due to the COVID-19 outbreak.” Id. ¶ 37. Using these funds, the state of New York implemented the ERAP and made OTDA responsible for approving ERAP applications and administering funds. Id. ¶ 9. OTDA is a pre-existing state agency responsible for providing financial assistance and support to eligible families and individuals. Id. ¶ 24. �e commissioner of the OTDA, at the time of the pandemic, was Barbara C. Guinn. Id. ¶ 25. Each state had the flexibility to structure and design their ERAP. Id. ¶ 44. Guinn, as commissioner of OTDA, established standards for determining eligibility for the ERAP in New York. Id. ¶ 49. OTDA required that to be eligible for benefits, one must be a “tenant or occupant obligated to pay rent in their primary residence in the state of New York … provided however that occupants of federal or state funded subsidized

1 Plaintiffs attached a list of NYCHA consumer debt claims on file in the New York State Supreme Court and NYCHA civil actions on file in the New York County Civil Court to the initial Complaint. Doc. 1. However, the FAC does not include the attachments. Doc. 40. public housing authorities or other federal or state funded subsidized housing that limits the household’s share of the rent to a set percentage of income shall only be eligible to the extent that funds are remaining after serving all other eligible populations.” Id. ¶ 49. In other words, individuals and households that were already receiving federal or state housing assistance would be deprioritized. In an effort to provide as many households as possible with ERAP funds, OTDA partnered with NYCHA. Id. ¶ 110. NYCHA is the largest public housing authority in North America, receives federal funding, and is subject to federal regulation. Id. ¶ 6. Together, OTDA and NYCHA established “a process that provided up to 12 months of financial relief to households that accumulated rent arrears at the height of the pandemic.” Id. ¶ 110, n. 99. In addition, Public Housing Authorities (“PHA”), funded by the U.S. Department of Housing and Urban Development (“HUD”), such as NYCHA, are expected to calculate the portion of rent a public and subsidized tenant must pay. Id. ¶¶ 52, 55. If there are any financial changes within a household, PHAs are expected to conduct an interim recertification within a reasonable period of time, that being no longer than 30 days after changes in income are reported. Id. ¶ 58. However, when NYCHA was informed of the financial hardship by Plaintiffs, NYCHA “failed to timely recertify their incomes and recalculate monthly rent payments to reflect this hardship,” leading residents to be charged rent that amounted to more than 30 percent of their household income, which exceeds the amount that public and subsidized housing residents are expected to pay in rent. Id. ¶¶ 8, 15. NYCHA has initiated consumer debt actions against NYCHA residents for unpaid, though miscalculated, rent. Id. ¶ 16. Plaintiffs assert that a class of Black and Hispanic or Latino residents living in NYCHA housing experienced economic hardship during the pandemic and were eligible for assistance through the ERAP, but were discriminated against because of their race, national origin, disability, and/or source of income. Id. ¶ 5. �e OTDA and Guinn allegedly intentionally discouraged eligible NYCHA residents from applying for ERAP through “numerous published statements prominently advertising their policy of deprioritizing public and subsidized housing applicants.” Id. ¶ 11. Instead, the OTDA and Guinn encouraged NYCHA residents to apply for OTDA loans to cover rent, which unlike ERAP funding, must be repaid. Id. ¶ 13. At the time ERAP funding ran out, many NYCHA residents had not received any financial benefit. Id. ¶ 10. Plaintiffs Wanda Baez and Siide Gil-Frederick were subsidized tenants living in NYCHA housing who experienced financial hardship, applied for ERAP in 2021, but received no benefits “at the height of the pandemic.” Id. ¶¶ 20, 21. Baez and Gil- Frederick did, however, receive ERAP benefits, for the maximum number of months available for subsidized tenants, in May 2024 and November 2023, prior to the commencement of this action, but after the height of the pandemic. Id. ¶¶ 20-21, 149; Doc. 18 ¶ 61. Plaintiff Danielle Johnson was a subsidized tenant living in NYCHA housing during the pandemic in 2021, experienced financial hardship, and “never received information about or was made aware of ERAP, and as such did not apply, though she would have wanted to and could have greatly benefited from assistance.” Id. ¶ 22. All three plaintiffs amassed thousands of dollars in rent arrears as a result of not receiving ERAP funding. Id. ¶¶ 20-22. Plaintiff RRPH, is “a 501(c)(3) member organization consisting of tenants who reside in public housing across the five boroughs of New York City,” advocates on behalf of thousands of NYCHA residents who experienced financial hardship, applied or wanted to apply for ERAP, and received no benefits. Id. ¶ 23. II. PROCEDURAL HISTORY Plaintiffs filed the initial complaint on April 30, 2024. Doc. 1. �e FAC was filed on July, 25, 2024. Doc. 40. �e FAC alleges seven causes of action asserting a violation of the FHA, Title VI of the Civil Rights Act of 1964, and New York State Human Rights Laws, as well as negligence. Id. NYCHA filed a motion to dismiss on August, 16, 2024, pursuant to Federal Rules of Civil Procedure 12(b)(1) for lack of standing,2 and 12(b)(6) for failure to state a claim. Doc. 51. Guinn and OTDA filed a motion to dismiss on September 27, 2024, also pursuant to Rules 12(b)(1) and 12(b)(6). Doc. 55. III. LEGAL STANDARD A.

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Baez v. New York State Office of Temporary and Disability Assistance, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baez-v-new-york-state-office-of-temporary-and-disability-assistance-nysd-2025.