Bashir Alhalemi v. City University of New York

CourtDistrict Court, S.D. New York
DecidedMarch 27, 2026
Docket1:24-cv-06975
StatusUnknown

This text of Bashir Alhalemi v. City University of New York (Bashir Alhalemi v. City University of New York) 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
Bashir Alhalemi v. City University of New York, (S.D.N.Y. 2026).

Opinion

USONUITTEHDE RSTNA DTIESST RDIICSTT ROIFC TN ECWOU YROTR K --------------------------------------------------------------X : BASHIR ALHALEMI, : Plaintiff, : : 24 Civ. 6975 (LGS) -against- : : OPINION & ORDER CITY UNIVERSITY OF NEW YORK, : Defendant. : : --------------------------------------------------------------X LORNA G. SCHOFIELD, District Judge: This Opinion & Order addresses the Report and Recommendation, dated November 18, 2025, of Magistrate Judge Robyn F. Tarnofsky (the “Report”). The Report recommends granting the Motion to Dismiss filed by Defendant City University of New York (“CUNY”) and granting Plaintiff Bashir Alhalemi leave to amend the complaint. For the reasons below, the Report is adopted as modified. I. BACKGROUND Plaintiff, proceeding pro se, commenced this action against Defendant on September 9, 2024. The Amended Complaint, the most recently filed complaint, asserts claims under Title II of the Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12131-121635 (Claim I), Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 (Claim II) and the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. L. §§ 290-301 (Claim III). The Amended Complaint seeks damages and declaratory and injunctive relief. A. Factual Background The following facts are taken from the complaints filed in this action and assumed to be true for purposes of the Motion to Dismiss. Herrera v. Comme des Garcons, Ltd., 84 F.4th 110, 113 (2d Cir. 2023). Given Plaintiff’s pro se status, it is appropriate to consider, as the Report did, allegations in the original Complaint as well as the Amended Complaint. Viera v. United States, No. 24 Civ. 1862, 2024 WL 2219434, at *2 n.1 (S.D.N.Y. May 14, 2024). For clarity, both complaints together are referred to as the “Complaint.” Plaintiff is a former student of Kingsborough Community College (“Kingsborough”), which Defendant operates. Plaintiff, who is visually impaired, uses a screen reader to access digital educational content, submit assignments and communicate with instructors and peers. Plaintiff had registered with Kingsborough’s accessibility office. In or around 2024, CUNY began using Brightspace as a learning management system. Brightspace is not fully compatible with screen readers, presenting several accessibility barriers to visually impaired users. Plaintiff encountered significant difficulties in accessing course

materials, submitting assignments, participating in discussions and completing coursework due to accessibility issues with Brightspace. Plaintiff sent an email to college staff to report these accessibility issues, but CUNY failed to take adequate steps to remedy these issues. Plaintiff ultimately withdrew from CUNY in September 2024, the same month he enrolled, because of Brightspace’s inaccessibility. B. The Report On November 18, 2025, Judge Tarnofsky issued the Report recommending that Defendant’s Motion to Dismiss be granted without prejudice to Plaintiff’s filing a Second Amended Complaint. The Report concludes that the Complaint fails to state a violation of the ADA or

Rehabilitation Act because the Complaint does not adequately allege that Defendant discriminated against Plaintiff. Specifically, the Report concludes that the Complaint does not pursue a theory of intentional discrimination or disparate impact, and the Complaint does not allege that Plaintiff requested an accommodation from Defendant. The Report concludes, in the alternative event that the Complaint does adequately allege that Plaintiff requested an accommodation, the Complaint alleges facts sufficient to state a claim for damages under the ADA and Rehabilitation Act. The Report also concludes that the Court should decline to exercise supplemental jurisdiction over the NYSHRL claim, or, in the alternative, that the NYSHRL claim should be dismissed because the Complaint did not allege that Plaintiff had timely served a notice of claim on Defendant. Plaintiff timely filed objections (the “Objections”). The Objections argue that the Report applies an improperly strict pleading standard; the Complaint adequately alleges a request for accommodation; Plaintiff provided a notice of claim to Kingsborough, which suffices to provide a notice of claim to Defendant and dismissal is unnecessary because any pleading defects

can be cured through amendment. II. STANDARD A reviewing court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1). “The district judge must determine de novo any part of the magistrate judge’s disposition that has been properly objected to.” Fed. R. Civ. P. 72(b)(3); accord 28 U.S.C. § 636(b)(1). De novo review means the district judge makes an independent determination of the portions of the Report that were properly objected to and does not defer to the magistrate judge’s conclusions. Even when exercising de novo review, “[t]he district court need not . . . specifically articulate its reasons for rejecting a party’s objections or for adopting a magistrate judge’s report and recommendation in

its entirety.” Morris v. Local 804, International Brotherhood of Teamsters, 167 F. App’x 230, 232 (2d Cir. 2006) (summary order);1 accord Bulgari v. Bulgari, No. 22 Civ. 5072, 2024 WL 4345580, at *2 (S.D.N.Y. Sep. 30, 2024).

1 Unless otherwise indicated, in quoting cases, all internal quotation marks, footnotes and citations are omitted and all alterations are adopted. To the extent the parties do not object to portions of a magistrate judge’s report and recommendation, the report is reviewed for clear error. See Nambiar v. Cent. Orthopedic Grp., LLP, 158 F.4th 349, 359 (2d Cir. 2025). When reviewing for clear error, the judge asks whether the report contains an obvious mistake. See M.L. v. Comm’r of Soc. Sec., No. 23 Civ. 5143, 2024 WL 404342, at *1 (S.D.N.Y. Feb. 2, 2024). Similarly, where no specific written objection is made, “the district court can adopt the report without making a de novo determination.” United States v. Male Juv., 121 F.3d 34, 38 (2d Cir. 1997); accord Shulman v. Chaitman LLP, 392 F. Supp. 3d 340, 345 (S.D.N.Y. 2019) (“A district court evaluating a magistrate judge’s report may adopt those portions of the report to which no specific written objection is made, as long as the

factual and legal bases supporting the findings and conclusions set forth in those sections are not clearly erroneous or contrary to law.”). “[P]ro se submissions are reviewed with special solicitude and must be construed liberally and interpreted to raise the strongest arguments that they suggest.” Barnes v. City of New York, 68 F.4th 123, 127 (2d Cir. 2023). But “pro se status does not exempt a party from compliance with relevant rules of procedural and substantive law.” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 477 (2d Cir. 2006); accord McKenzie-Morris v. V.P. Recs. Retail Outlet, Inc., No. 22 Civ. 1138, 2023 WL 5211054, at *5 (S.D.N.Y. Aug. 13, 2023).

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Bashir Alhalemi v. City University of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bashir-alhalemi-v-city-university-of-new-york-nysd-2026.