Jeffrey Scott Steinberg v. Kathi Vidal, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office

CourtDistrict Court, E.D. New York
DecidedFebruary 21, 2026
Docket2:22-cv-04971
StatusUnknown

This text of Jeffrey Scott Steinberg v. Kathi Vidal, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office (Jeffrey Scott Steinberg v. Kathi Vidal, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office) 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
Jeffrey Scott Steinberg v. Kathi Vidal, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office, (E.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------------X JEFFREY SCOTT STEINBERG,

Plaintiff, REPORT AND RECOMMENDATION -against- CV 22-4971 (JMA)(AYS)

KATHI VIDAL, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office,

Defendant. ------------------------------------------------------------------X APPEARANCES:

Jeffrey Scott Steinberg, Plaintiff Pro Se

VINCENT LIPARI, ESQ. United States Attorneys Office Easter District of New York 610 Federal Plaza Central Islip, New York 11722-4454 Attorneys for Defendant

SHIELDS, Magistrate Judge: Plaintiff Jeffery Steinberg (“Plaintiff”) commenced this action against his former employer, the United States Patent and Trademark Office (the “PTO”) alleging disability discrimination in violation of the Rehabilitation Act of 1973, 29 U.S.C. §§ 791, 794. See generally Amended Complaint filed herein appearing as Docket Entry herein (“DE”) [8]. Plaintiff alleges both direct discrimination and retaliation on account of his disability. Presently before this Court, on referral from the District Court for Report and Recommendation, is Defendant’s motion for summary judgment. See DE [42]. For the reasons set forth below this Court respectfully recommends that the motion be granted. BACKGROUND I. Basis of Facts Recited Herein Facts forming the basis of decisions on motions for summary judgment motions are meant to be derived from the parties’ competing statements of material fact submitted pursuant to Rule 56.1 of the Local Rules of the United States District Courts for the Southern and Eastern

Districts of New York. Consideration of such statements allows the Court to streamline the summary judgment process by identifying facts in dispute, as well as those agreed up by the parties. Parties appearing pro se are not excused from submission of Rule 56.1 statements, so long as the moving Defendant has properly provided the non-moving party with a notice compliant with Local Rule 56.2. That notice has been provided to Plaintiff here. See DE [42] at 3. Despite Defendant’s compliance with Rules 56.1 and 56.2, Plaintiff has failed to submit a Rule 56.1 statement. He has instead submitted only a memorandum in opposition to the motion. In deciding this motion this Court will consider that memorandum, Defendant’s Rule 56.1 Statement, as well the documents annexed thereto that are properly placed before the Court.

II. The Parties and Plaintiff’s Employment at the PTO The PTO is the agency responsible for granting and issuing patents, registering trademarks, and disseminating information concerning patents and trademarks to the public. DE [42-2] at ¶ 5. Plaintiff was an employee of the PTO from 2008 until his 2018 termination. Plaintiff was first employed as an Assistant Patent Examiner. Id. at ¶ 7. His duties then consisted of examining patent applications to determine whether they met the statutory and regulatory requirements for the issuance of a patent. Plaintiff was later employed as a Patent Examiner, with the same scope of duties. During the course of his employment Plaintiff was not authorized to approve or reject patent applications. Rather, he reviewed applications and provided comments and recommendations to a Supervisory Patent Examiner (“SPE”). Those supervisors would then provide edits, corrections and comments to Plaintiff’s work. When Plaintiff began to work remotely, all such comments and edits were exchanged remotely through the PTO’s computer system. Id. at ¶ 8 III. Plaintiff’s Disability

The Court assumes that at all times during his employment at the PTO Plaintiff was disabled in the manner that he describes in his Amended Complaint. As discussed therein and as Plaintiff’s employment records and testimony make clear, Plaintiff’s disability stems from a severe traumatic brain injury (“TBI”) which is traced to a near-fatal car accident that took place on July 22, 1984 - more than twenty years prior to the 2008 commencement of Plaintiff’s employment at the PTO. As discussed in Plaintiff’s pleading and briefly stated herein, Plaintiff suffered a fracture of the right rear hemisphere of his skull. Since the 1984 accident that resulted in his TBI, Plaintiff has undergone several surgeries. The final such procedure is stated to have healed in August of 2022. Plaintiff states that his gait impairment remains noticeable, but is far

less severe than in the past. As his many requests for accommodation discussed below make clear, Plaintiff has, over the years of his employment, experienced difficulty walking. This has impacted his ability to commute to the Alexandria, Virginia office where he was initially employed. Despite clear and consistent evidence describing Plaintiff’s disability as physical in nature, i.e., relating to his ability to walk to and around his place of work, Plaintiff’s Amended Complaint states that his TBI seriously affects his ability to process information quickly, and that prolonged interactions result in verbal and physical fatigue. This pleading and the submission of a 2016 physician’s note hint that Plaintiff’s claimed disability is mental as well as physical. All of the other factual evidence submitted in connection with the present motion, however, state otherwise. These facts demonstrate that the disability for which accommodation was sought was physical in nature, and in no way impacted Plaintiff’s ability to perform his job. Thus, Plaintiff’s deposition testimony, self-reported stellar work performance, and the nature of his several years of accommodation requests (spanning from 2009 through 2013) all belie the notion that any

mental disability or difficulty interfered with Plaintiff’s ability to perform the functions required of the highly technical and skilled work of a Patent Examiner. Plaintiff’s deposition testimony is consistent with the physical nature of his disability. When asked at his deposition whether his disability caused any limitations in his “mental ability” Plaintiff first responded “Yes, I would think so”. Deposition Transcript of Jeffrey Steinberg dated 8/27/2024 (“Steinberg Tr.”), DE [42-3] at 21:21. However, he clarified that this response referred to a “[l]ack of social interaction because of the way in which people perceive disabled people.” Id. at 21:21-23. Plaintiff went on to testify that he did not think that he suffered limitations in mental abilities. Id. at 22:6. Plaintiff’s requests for accommodation are also consistent with the

fact that Plaintiff’s disability affected his abilities to commute and walk around the PTO campus, but did not limit his ability to properly perform his work or communicate with his supervisors. Plaintiff’s testimony as to his work success is similarly consistent with a finding that he did not need any accommodation to address any intellectual or cognitive difficulty when performing his duties as a Patent Examiner. Thus, Plaintiff testified at his deposition that prior to 2015 he was performing “fantastically well” “was doing great” and that there “was never an issue.” Steinberg Tr. at 19:17-18; 34:13; 53:14. He further testified that he did not believe that his disability affected his work performance. Id. at 21:21-24:22; 34:10-20. Plaintiff’s 2009-2013 requests for accommodation, discussed below, further support the conclusion that he never claimed anything other than accommodation for a physical disability. All such requests for accommodation were granted. IV. Plaintiff’s Requests for Accommodation: 2009-2013 During the course of his employment Plaintiff made several requests for workplace

accommodation.

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Jeffrey Scott Steinberg v. Kathi Vidal, Performing the Functions and Duties of the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffrey-scott-steinberg-v-kathi-vidal-performing-the-functions-and-duties-nyed-2026.