Bosman v. McDonough

CourtDistrict Court, E.D. New York
DecidedAugust 14, 2025
Docket2:24-cv-05124
StatusUnknown

This text of Bosman v. McDonough (Bosman v. McDonough) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bosman v. McDonough, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT 8/14/2 025 EASTERN DISTRICT OF NEW YORK U.S. DISTRICT COURT --------------------------------------------------------------X EASTERN DISTRICT OF NEW YORK SANDY BOSMAN, LONG ISLAND OFFICE Plaintiff, MEMORANDUM AND ORDER 24-CV-05124 (JMW) -against- DENIS R. MCDONOUGH, Secretary of the Dept. of Veterans Affairs, and MERIT SYSTEM PROTECTION BOARD (NY), Defendants. --------------------------------------------------------------X A P P E A R A N C E S: Sandy Bosman 2719 44th Drive, Apt. #5A Long Island City, NY 11101 Plaintiff Appearing Pro Se Diane C. Leonardo United States Attorney’s Office 610 Federal Plaza Central Islip, NY 11722 Attorney for Defendants WICKS, Magistrate Judge: Pro se Plaintiff Sandy Bosman (“Plaintiff”) commenced this action on June 4, 2024, against Denis R. McDonough—Secretary of the Department of Veterans Affairs (“VA”)—and the Merit System Protection Board (“MSPB”) (collectively, “Defendants”) asserting claims for: (1)employment discrimination under Title VII; (2) intentional employment discrimination on the basis of race pursuant to 42 U.S.C. § 1981; (3) employment discrimination pursuant to the New York State Human Rights Law (“NYSHRL”) and New York City Human Rights Law (“NYCHRL”); and (4) defamation of character, slander, and employment harassment. (ECF No. 1 at pp. 3-4.) Before the Court1 is Defendants’ motion to dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6). (ECF No. 29.) For the following reasons, Defendants’ motion (ECF No. 29) is GRANTED.

BACKGROUND Plaintiff is a former nursing assistant at the VA’s Medical Center in Northport, New York. (See ECF No. 1 at p. 3.) She asserts that Defendants engaged in racially discriminatory actions towards employees of color, like herself. (See id.) Specifically, Plaintiff notes that Defendants allegedly terminated her employment, retaliated against her, harassed her, created a hostile work environment, and defamed her character through false accusations. (Id. at p. 5.) As such, Plaintiff requests that Defendants re-hire her and seeks money damages on grounds that she no longer receives medical or health benefits, she cannot sleep at night, and she is unable to maintain another job. (Id. at p. 6.) Plaintiff, through her Complaint, demonstrates how her case is presently before the

Court. On August 10, 2023, the VA issued a decision to remove Plaintiff effective August 20, 2023. (See id. at Ex. A, p. 1.) Plaintiff then appealed her removal to the MSPB on November 13, 2023. (See id.) On April 16, 2024, the MSPB rejected Plaintiff’s case without reaching a decision on the merits of any of her claims due to her significant delay in filing her appeal. (See id. at p. 2.) Plaintiff should have filed with the MSPB within 30 days of her termination (September 19, 2023), yet Plaintiff instead filed her appeal on November 13, 2025, fifty-five days late. (Id.) Moreover, Plaintiff failed to show good cause justifying the delay. (Id.) As such, the MSPB appeal was dismissed with an effective date of April 16, 2024. (See ECF No. 31-3, Ex. C at p. 5.)

1 The parties consented to the jurisdiction of the undersigned for all purposes on September 29, 2024. (ECF Nos. 23, 25 (so-ordered consent form)). Plaintiff appealed this final decision by the MSPB to the Equal Employment Opportunity Commission (“EEOC”). (ECF No. 1, Ex. A at p. 2.)2 The EEOC also denied Plaintiff’s case for lack of jurisdiction over the appeal pursuant to applicable EEOC regulations because the MSPB dismissed Plaintiff’s appeal as untimely and thus did not address the merits of any employment

discrimination claims. (Id. (EEOC noting that the MSPB’s decision “did not address any matters within the Commission’s jurisdiction”)). Subsequently, Plaintiff received a “Notice of Right to Sue” from the EEOC on May 6, 2024, advising Plaintiff that she had “the right to file a civil action in an appropriate United States District Court, based on the decision of the [MSPB], within thirty (30) calendar days of the date that you receive this decision.” (Id. at p. 3.) Plaintiff commenced the underlying lawsuit3 on June 4, 2024, it appears in response to the EEOC’s denial of Plaintiff’s MSPB claim. (See ECF No. 1 at p. 5 (“MSPB deny [sic] my case and I appealed the MSPB [sic] with the EEOC and they deny my appeal and am pursuing this process to the last result.”)). Despite being advised by the EEOC of her right to request counsel (see ECF No. 1, Ex. A at p. 3), Plaintiff is appearing in

this action pro se. Following an Initial Conference before the undersigned on September 9, 2024, Defendants filed their motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6) (ECF Nos. 29-31) and Plaintiff’s opposition (ECF No. 32) on January 23, 2025. No reply was submitted. (See ECF No. 33 at p. 1.)

2 For the sake of clarity in pagination, the Court refers to the EEOC decision within Plaintiff’s Complaint as “Ex. A” and notes the page numbers of the EEOC decision accordingly.

3 Plaintiff brough this action initially in the United States District Court for the Southern District of New York but, pursuant to the parties’ stipulation, the matter was transferred to this Court. (ECF Nos. 14, 15.) On March 11, 2025, Plaintiff submitted a letter4 “formally object[ing] to the recent Dismissal ruling in [her] case.” (ECF No. 35 at p. 1.) Since the case had not been dismissed at that stage, the Court held a status conference on March 21, 2025, at which the Court explained to Plaintiff that only a motion to dismiss was pending and the case had not been dismissed. (ECF

No. 37.) Plaintiff was also afforded the additional opportunity to present any further information, documents, evidence or arguments in opposition to the pending motion, but none was filed. (Id.) DISCUSSION A. Failure to Exhaust Administrative Remedies Though Defendants argue that Plaintiff did not exhaust her administrative remedies as she was obligated to do (ECF No. 30 at p. 14), Plaintiff does not address that argument. (See generally ECF No. 32.) “[C]ourts construe motions to dismiss for failure to exhaust administrative remedies as Rule 12(b)(6) motions for failure to state a claim, rather than Rule 12(b)(1) motions for lack of

subject matter jurisdiction.” D'Amato v. Soc. Sec. Admin., No. 21-CV-5778 (DG) (ST), 2024 WL 4648145, at *4 (E.D.N.Y. Aug. 29, 2024), report and recommendation adopted, 2024 WL 4648140 (E.D.N.Y. Sept. 20, 2024); see Bolt v. Planned Parenthood of Cent. & W. New York, 763 F. Supp. 3d 463, 470 n.1 (W.D.N.Y. 2025) (analyzing an exhaustion of administrative remedies argument under Rule 12(b)(6) because “the failure to exhaust administrative remedies is a precondition to bringing a Title VII claim in federal court rather than a jurisdictional requirement”) (quoting Francis v. City of New York, 235 F.3d 763, 768 (2d Cir. 2000)). “[C]ourts in this Circuit routinely dismiss complaints at the Rule 12(b)(6) stage for failure to

4 Pro se Plaintiff emailed this letter to the undersigned’s Chambers on March 13, 2025. The undersigned docketed the letter on ECF the same day. (ECF No. 35.) exhaust administrative remedies under the CSRA and Title VII—including claims brought by federal employees proceeding pro se—where such failure is clear from the face of the complaint.” Wilder v. Shulkin, No. 14-CV-10072 (RJS), 2017 WL 2889507, at *5 (S.D.N.Y. June 30, 2017).

Employees alleging adverse action based on discrimination under the Civil Service Reform Act (“CSRA”) may either bring a mixed complaint through the EEOC or bring a mixed appeal before the MSPB.

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Bluebook (online)
Bosman v. McDonough, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bosman-v-mcdonough-nyed-2025.