DIAMONTE v. HENDERSON

CourtDistrict Court, D. New Jersey
DecidedApril 3, 2025
Docket2:23-cv-03596
StatusUnknown

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

Bluebook
DIAMONTE v. HENDERSON, (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

MARIA DIAMONTE,

Plaintiff, Civil No.: 2:23-cv-03596 (KSH) (SDA)

v. TAJA NIA HENDERSON; KINNA PERRY; GARY FARNEY; JACQUELINE MATTIS; RUTGERS, THE STATE UNIVERSITY OF NEW JERSEY; THE BOARD OF GOVERNORS OF RUTGERS, THE STATE OF NEW JERSEY; RUTGERS UNIVERSITY OPIN ION FOUNDATION OF THE STATE UNIVERSITY; JOHN DOE 1-100 (names being fictitious); JANE DOE 1-100 (names being fictitious), individually and in their professional capacities,

Defendants.

Katharine S. Hayden, U.S.D.J. I. Introduction Plaintiff Maria Diamonte has sued Rutgers University and a host of individual defendants, alleging various federal and state civil rights claims based on the university’s decision not to grant her a further extension to complete her doctoral dissertation. Her amended complaint asserted thirteen claims, seven of which remain and are now before the Court on defendants’ motion to dismiss.1 The remaining claims allege violation of the Rehabilitation Act of 1973 (“RA”), 29 U.S.C. § 701 et seq. (Count Three); the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12131 et seq. (Counts Four and Eleven), 42 U.S.C. § 1983 (“Section

1 As discussed infra, plaintiff’s counsel acknowledged at oral argument that the other counts have been waived. 1983”) for violating an unspecified federal law (Count Five), Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e et seq. (Counts Eight and Thirteen), and the Equal Protection Clause of the federal constitution (Count Ten). For the reasons set forth below, the amended complaint will be dismissed in its entirety.

II. Background The amended complaint (D.E. 15, Am. Compl.), alleges that Diamonte was a PhD candidate in the Division of Global Affairs (“DGA”) at Rutgers University, Newark (“Rutgers”). As of July 2022, Diamonte was “trying to finish her dissertation to fulfill the final requirements for the PhD degree,” having gotten a number of previous extensions to do so. (Id. ¶ 8; D.E. 34-3, Colao Dec., Ex. A (Diamonte Verified Complaint to DCR (“DCR Compl.”)).)2 According to defendants, she had been enrolled in the program for approximately 11.5 years, or 23 cumulative semesters. (D.E. 34-1, Defs.’ Moving Br. at 2; D.E. 34-4, Colao Dec., Ex. B (Rutgers Response to DCR Complaint (“DCR Response”)).) She claims Rutgers unlawfully denied her an extension of time to complete her dissertation and be awarded her degree. (Am. Compl. ¶ 1; D.E. 34-1,

Defs.’ Moving Br. at 2.) Specifically, Diamonte asserts Rutgers discriminated against her by denying the extension request based on her disabilities, which include “severe fatigue and migraines, autoimmune conditions, endocrine, and heart issues.” (Am. Compl. ¶¶ 5, 11, 13, 30.)

2 The contents of the DCR documents attached to defendants’ motion to dismiss are permissibly considered at the motion to dismiss stage because they are integral to plaintiff’s claims. See Chugh v. Western Inventory Servs., Inc., 333 F. Supp. 2d 285, 289 (D.N.J. 2004) (Linares, J.) (considering DCR investigation documents attached to the defendant’s motion to dismiss that were “incorporated into the pleadings by reference” and “integral to or upon which plaintiff’s claim is based”); S. Cross Overseas Agencies, Inc. v. Kwong Shipping Grp. Ltd., 698 F. Supp. 3d 766, 772 (3d Cir. 1999) (finding that “a court may consider an undisputedly authentic document that a defendant attaches as an exhibit to a motion to dismiss if the plaintiff’s claims are based on the document”). Well before this action was filed, Diamonte pursued relief by way of a verified complaint she filed with the New Jersey Division on Civil Rights (“DCR”), alleging violations of the New Jersey Law Against Discrimination (“NJLAD”), N.J.S.A. § 10:5-1 et seq. based on disparate treatment, failure to accommodate, and retaliation. (DCR Compl. at 1-2.) She alleged there that

Rutgers did not require non-disabled students to apply for extensions of time, but did require her to apply because of her disability status. (Id. at 2.) On January 25, 2023, the DCR found no probable cause existed to credit the allegations in Diamonte’s complaint and closed the file. (D.E. 34-5, Colao Dec., Ex. C (“DCR Decision”).) Within months, on June 6, 2023, Diamonte initiated this action, naming as defendants Rutgers and various individual defendants—graduate school deans Perry, Taja Nia Henderson, and DGA’s department chair Gary Farney—as well as the Board of Governors of Rutgers. (D.E. 1.) On January 12, 2024, she filed the operative amended complaint adding as defendants Rutgers dean Jacqueline Mattis and Rutgers University Foundation of the State University. (D.E. 15.) As noted earlier, Diamonte asserts claims for violation of the RA (Count Three), the

ADA (Counts Four and Eleven), Section 1983 (Count Five), Title VII (Counts Eight and Thirteen), and the Equal Protection Clause (Count Ten). The amended complaint also asserted claims for race discrimination under the NJLAD (Count One); failure to accommodate, also under the NJLAD (Count Two); negligent and/or intentional infliction of emotional distress (Count Six); disability discrimination under the NJLAD and ADA (Count Seven); violation of an unspecified federal law under 42 U.S.C. § 1981 (Count Nine); violation of free speech rights under the First Amendment (Count Ten); and breach of an unidentified contract (Count Twelve). Defendants moved to dismiss all of the foregoing claims, arguing in pertinent part, that Counts Three, Four, and Eleven are barred by either the election of remedies provision contained within the NJLAD or issue preclusion; that Counts Five and Ten fail to allege a viable legal theory or plausibly allege facts that would warrant relief; and that Counts Eight and Thirteen fail because plaintiff has not, and cannot, plead an employer/employee relationship with Rutgers, an essential element of those claims. (D.E. 34-1, Defs.’ Moving Br.)

Diamonte opposed, countering that the DCR’s decision is “non-final” and has not been reviewed by a state court, which she contends must foreclose issue preclusion; that she was discriminated against based on her race; and that she was deprived of post-graduate employment positions, which, she posits, supports her Title VII claim. (D.E. 45, Pl.’s Opp. Br.) The Court heard oral argument on February 26, 2025. In response to the Court’s questions, plaintiff’s counsel conceded that by not responding to defendants’ arguments for dismissal of Counts One, Two, Six, Seven, Nine, Ten, and Twelve, plaintiff had waived those claims and that they would be dismissed. As such, the Court will dismiss those claims and proceeds below to consider the substance of the remaining claims. See, e.g., D.A. v. Finish Line, Inc., 2022 WL 7989391, at *2, *5 (D.N.J. Oct. 14, 2022) (Kugler, J.) (“[T]he failure to respond to a substantive argument to

dismiss a count, when a party otherwise files opposition, results in a waiver of that count.”). III. Standard of Review When deciding a motion to dismiss under Fed. R. Civ. P. 12

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DIAMONTE v. HENDERSON, Counsel Stack Legal Research, https://law.counselstack.com/opinion/diamonte-v-henderson-njd-2025.