Feliciano v. Aguirre

District Court, S.D. New York·Decided January 13, 2025·No. 1:24-cv-07636·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MICHAEL FELICIANO, Plaintiff, 24-CV-7636 (LTS) -against- ORDER OF DISMISSAL WITH LEAVE TO REPLEAD ANDRES AGUIRRE, Defendant. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action under the Fair Housing Act and Title II of the Americans with Disabilities Act, alleging that a Section 8 representative refused to accept his request for a reasonable accommodation in his housing. By order dated October 17, 2013, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth below, the Court dismisses the complaint for failure to state a claim but grants Plaintiff 30 days to file an amended complaint. The Court also refers Plaintiff to the City Bar Justice Center’s Pro Se Law Clinic. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the

pleader is entitled to relief. Rule 8 of the Federal Rules of Civil Procedure requires a complaint to include enough facts to state a claim for relief “that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if the plaintiff pleads enough factual detail to allow the Court to draw the inference that the defendant is liable for the alleged misconduct. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. After separating legal conclusions from well-pleaded

factual allegations, the Court must determine whether those facts make it plausible – not merely possible – that the pleader is entitled to relief. Id. BACKGROUND The following facts are drawn from the complaint.1 On May 23, 2024, Plaintiff “visited the department of housing preservation and development at 100 gold street . . . [t]o submit a reasonable accommodation request form for a emergency move due to his medical and mental health issues worsening.” (ECF 1, at 5.) Plaintiff explained to Defendant, Andres Aguirre, an

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. employee at the office, “that [Plaintiff’s] landlord was not following any of the lease agreements and felt the urgent need to move for his safety and bad living conditions in his apartment.” (Id.) Plaintiff further explained to Aguirre “that his physical and mental health conditions w[]ere worsening because of it.” (Id.) Plaintiff “then handed the defendant his completed reasonable accommodation form to the defendant.” (Id.) Aguirre reviewed the form “for less than 30

seconds and handed it back to [Plaintiff] then gave [Plaintiff] a non emergency regular move request for [Plaintiff] to fill out along with a letter of acknowledgement of [Plaintiff’s] participation in the section 8 program.” (Id. at 6.) Plaintiff asked Aguirre “why he was not processing his reasonable accommodation request . . . [and] [t]he defendant told [Plaintiff] to just use the one he gave him and ignored [his] request [t]o honor the reasonable accommodation request.” (Id.) For relief, Plaintiff seeks $76,000 in compensatory damages, punitive damages, and an order directing “defendant to process petitioners reasonable accommodation request.” (Id.) Plaintiff attaches to the complaint his signed reasonable accommodation request, which

states, “Only complete requests that explain the connection between the disability and the requested accommodation will be approved.” (Id. at 8.) Plaintiff provides nothing demonstrating that he explained the connection between his disability and the requested accommodation. DISCUSSION Plaintiff alleges that Aguirre violated the Fair Housing Act (“FHA”) and Title II of the Americans with Disabilities Act (“ADA”) when he did not accept Plaintiff’s reasonable accommodation request and instead instructed Plaintiff to complete a move form. As discussed below, the Court finds that Plaintiff does not state a claim under either statute and dismisses Plaintiff’s FHA and ADA claims for failure to state a claim on which relief may be granted. In light of Plaintiff’s pro se status, the Court grants him 30 days’ leave to file an amended complaint. A. Fair Housing Act Under the FHA, it is unlawful “[t]o discriminate in the sale or rental, or to otherwise make unavailable or deny, a dwelling to any buyer or renter because of a handicap of that buyer

or renter,” or “[t]o discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling . . . because of a handicap of that person.” 42 U.S.C. § 3604(f)(1)(A) and (2)(A). Prohibited discrimination under the FHA includes “a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling.” 42 U.S.C. § 3604(f)(3)(B); see also 24 C.F.R. 100.204(a). “[O]rdinarily, the duty to accommodate is shaped by the handicap,” because “it is the handicap that is accommodated.” Salute v. Stratford Greens Garden Apartments, 136 F.3d 293, 301 (2d Cir. 1998).

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