Holly Jarvis v. National Labor Relations Board, et. al.

CourtDistrict Court, N.D. New York
DecidedApril 2, 2026
Docket5:26-cv-00252
StatusUnknown

This text of Holly Jarvis v. National Labor Relations Board, et. al. (Holly Jarvis v. National Labor Relations Board, et. al.) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holly Jarvis v. National Labor Relations Board, et. al., (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK _____________________________________________________________________ Holly Jarvis,

Plaintiff, v. 5:26-CV-252 (MAD/MJK)

National Labor Relations Board, et. al.

Defendants. _____________________________________________________________________ Holly Jarvis, pro se

Mitchell J. Katz, U.S. Magistrate Judge

To the Honorable Mae A. D’Agostino, U.S. District Judge:

ORDER & REPORT- RECOMMENDATION Jarvis began this action on February 18, 2026, by filing a complaint, and moving for leave to proceed in forma pauperis (“IFP”) (Dkts. 1, 2). The Clerk sent Jarvis’s Complaint and IFP application to this Court for review. (Dkts. 1, 2). I. BACKGROUND During the 2024–25 work season, Jarvis allegedly “experienced workplace misconduct including unfair write-ups, favoritism in scheduling, inequitable treatment of tips, volunteers receiving better compensation and benefits than employees, and a hostile work environment.” (Dkt. 1, at ¶13) (cleaned up). She states that she reported these issues to human resources around “April–May 2025.” (Dkt. 1, at ¶14) (emphasis removed). Jarvis then allegedly submitted her

complaint in writing and provided a copy to her direct supervisor. (Dkt. 1, at ¶15). “[N]o investigation or corrective action was taken.” (Dkt. 1, at ¶16).

Jarvis then sought assistance from her labor union—Local 150. (Dkt. 1, at ¶17). Around June 2025, Jarvis “submitted complaints to the

union alleging failure of representation, employer favoritism, retaliation, and ongoing unfair labor practices.” (Dkt. 1, at ¶18). The union allegedly failed to represent Jarvis or correct the misconduct.

(Dkt. 1, at ¶19). Jarvis states that she was then “retaliated against, including being excluded from seasonal work and not being called back, resulting in financial and emotional harm.” (Dkt. 1, at ¶20).

After allegedly exhausting internal and union remedies, Jarvis filed an unfair labor practice complaint with the NLRB. (Dkt. 1, at ¶21). Jarvis states that she “communicated” with Besantis, who had received

her complaint. (Dkt. 1, at ¶22). She also states that she “communicated” with Metzger, who had received her complaint. (Dkt. 1, at ¶23). Jarvis then allegedly spoke with “an unnamed male NLRB employee who stated that he handled incoming mail and informed Jarvis that the NLRB office had been closed for remodeling for several weeks.” (Dkt. 1,

at ¶24) (cleaned up). The unnamed male employee located Jarvis’s mailed complaint and returned it to her “approximately one month later.” (Dkt. 1, at ¶25) (emphasis removed).

On December 11, 2025, Jarvis states that she contacted the NLRB Office of Congressional and Public Affairs “to escalate the matter,

explaining the full history of ignored complaints and retaliation.” (Dkt. 1, at ¶27). The NLRB allegedly “responded only with a generic form email, failing to address Jarvis’s specific allegations or the agencies

prior inaction.” (Dkt. 1, at ¶28). Jarvis states that, as of the filing of this Complaint, “the NLRB has taken no substantive action on [her] complaints.” (Dkt. 1, at ¶29).

II. IFP APPLICATION Jarvis declares in her IFP application that she is unable to pay the filing fee. (Dkt. 2). After reviewing her application, this Court finds Jarvis is financially eligible for IFP status. III. STANDARD OF REVIEW In addition to determining whether plaintiffs meet the financial criteria to proceed IFP, courts must also review the sufficiency of the

allegations in the complaint under 28 U.S.C. § 1915. That statute requires a court to dismiss a case “at any time” if it determines that the action is (1) frivolous or malicious; (2) fails to state a claim on which

relief may be granted; or (3) seeks monetary relief against a defendant who is immune from such relief. See 28 U.S.C. § 1915 (e)(2)(B)(i)-(iii).

When determining whether an action is frivolous, courts must consider whether the complaint lacks an arguable basis in law or in fact. See Neitzke v. Williams, 490 U.S. 319, 325 (1989), abrogated on

other grounds by Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007); 28 U.S.C. § 1915. Dismissal of frivolous actions is appropriate to prevent abuses of court process and to discourage the waste of judicial

resources. Neitzke, 490 U.S. at 327; Harkins v. Eldredge, 505 F.2d 802, 804 (8th Cir. 1974). Courts have a duty to show liberality toward pro se litigants and

must use extreme caution when sua sponte dismissing pro se complaints before adverse parties have been served and had an opportunity to respond. See Fitzgerald v. First E. Seventh St. Tenants Corp., 221 F.3d 362, 363 (2d Cir. 2000) (finding that a district court may dismiss a

frivolous complaint sua sponte even when plaintiff has paid the filing fee). But courts still have a responsibility to determine that a claim is not frivolous before permitting a plaintiff to proceed. See id.

IV. DISCUSSION The District Court should dismiss Jarvis’s Complaint for four reasons. First, the District Court lacks jurisdiction to review Jarvis’s

Complaint. Second, the APA does not generally allow judicial review of NLRB decisions. Third, Jarvis has failed to state a claim on which relief can be granted. Fourth and finally, Jarvis is not entitled to mandamus.

In consequence, the District Court should dismiss Jarvis’s Complaint. A. The District Court lacks jurisdiction over Jarvis’s case against the NLRB.1 The District Court should dismiss Jarvis’s Complaint as to the NLRB for two reasons. First, the District Court lacks authority to

1 The Office of Congressional and Public Affairs, NLRB, is part of the NLRB’s internal organization. Neither the NLRA nor case law suggests that it is an independent body that is amenable to suit. See, e.g., Jamestown Veneer & Plywood Corp. v. NLRB, 13 F. Supp. 405, 407 (W.D.N.Y. 1936) (explaining that the NLRB “is a body corporate with legal capacity to be a party plaintiff or defendant in the federal courts insofar as the statute gives the right of suit.”) (cleaned up). review the NLRB’s prosecution decisions. Second, district courts generally lack jurisdiction over NLRB cases. Therefore, the District

Court should dismiss Jarvis’s Complaint for lack of jurisdiction. First, Jarvis’s Complaint fails because judicial review is unavailable for NLRB prosecution decisions. The NLRB is governed by

the NLRA. See 29 U.S.C. § 151 et seq. The NLRA “differentiate[s] between ‘prosecutorial’ determinations, to be made solely by the

General Counsel and which are not subject to review under the [NLRA], and ‘adjudicatory’ decisions, to be made by the [NLRB] and which are subject to judicial review.” NLRB v. United Food & Commercial

Workers Union, Local 23, 484 U.S. 112, 129–130 (1987). For prosecutions, the NLRA gives the NLRB General Counsel “final authority” concerning “the filing, investigation, and prosecution of

unfair labor practice complaints.” Id. at 114 (cleaned up). Basically, “the NLRA is meant to be, and is, a comprehensive statute concerning the disposition and review of the merits of unfair labor practice charges”

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