Jules v. The City of New York

CourtDistrict Court, S.D. New York
DecidedJune 2, 2025
Docket1:24-cv-10056
StatusUnknown

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

Bluebook
Jules v. The City of New York, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JOSEPHINE JULES, Plaintiff, 24-CV-10056 (KMW) -against- ORDER OF DISMISSAL THE CITY OF NEW YORK, WITH LEAVE TO REPLEAD Defendant. KIMBA M. WOOD, United States District Judge: Plaintiff, appearing pro se, brings this action alleging that the City of New York violated her rights following the September 11, 2001 attacks by failing to protect her from hazardous conditions that posed a risk to her health. By order dated January 15, 2025, ECF No. 7, the court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the following reasons, the Court dismisses the complaint for lack of subject matter jurisdiction, with 30 days’ leave to replead.

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 over the claims raised. See Fed. R. Civ. P. 12(h)(3). Although 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 to interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (per curiam) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” courts provide to pro se litigants, 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. Fed. R. Civ. P. 8(a)(2). 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. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true, but it need not accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Id. at 678-79. . 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. at 679.

BACKGROUND The following facts are drawn from the amended complaint.1 On September 11, 2001, Plaintiff, who states that she resides in New York but is a citizen of Sweden, lived in an apartment at 100 John Street, near the World Trade Center (“WTC”), until March 2002. (ECF 6

1 On January 10, 2025, Plaintiff filed an amended complaint. The Court quotes from this pleading verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. The Court uses standard capitalization for readability purposes. ¶¶ 68, 77.) “[B]eginning on September 12, 2001, Plaintiff . . . relied on . . . the City of New York insistences and assurances that air quality at and around the WTC disaster site was safe and of no concern for health, and denials of hazards.” (Id. ¶ 69.) By relying on the City’s assurances, Plaintiff “was caused to suffer exposure(s) and inhalation(s) of WTC toxic environmental contaminants and hazards and environmental toxicants released into the air[.]”

(Id. ¶ 71.) Plaintiff contends that “as a result” of her exposure, she “sustained serious latent injuries, threatening to shorten her life and afflict her remaining years.” (Id.) These injuries include, “Interstitial Lung Abnormalities, Interstitial Lung Disease, Myositis, Mixed or Undifferentiated Connective Tissue Disease, Rheumatologic systemic Autoimmune disease, Bronchiectasis, Cerebrovascular Accident (CVA) Lacunar Infarct, and Cerebral Microangiopathy.” (Id. ¶ 75.) She indicates that she has received medical care in New York City from November 2022 to the present. She also indicates that she received care in Sweden in November 2019, and in Canada in 2016, and in 2019.

Plaintiff asserts state law claims. Plaintiff filed a notice of claim in state court, and “on June 18, 2024, and July 8, 2024, and July 17, 2024, pursuant to Municipal Law[,] a 50-H hearing was taken . . . via Zoom.” (Id. ¶ 4.) Plaintiff commenced this action “within one year and ninety days after accrual of this cause of action.” (Id. ¶ 5.) Plaintiff seeks money damages.

DISCUSSION This action involves state law claims arising from the City of New York’s alleged conduct following the September 11, 2001 attacks. As discussed below, the Court may exercise subject matter jurisdiction over Plaintiff’s claims only under the diversity of citizenship statute. Because Plaintiff alleges that she and Defendant both reside in New York, the Court lacks jurisdiction over her claims. A. Plaintiff’s claims must be brought as state law claims In the weeks after September 11th, Congress passed the Air Transportation Safety and System Stabilization Act of 2001 (“ATSSSA”) to provide victims and their families an expedient

method of recovery while also protecting the airlines against exposure to financial ruin. See Pub. L. 107-42, 115 Stat. 230 (Sept. 22, 2001) (codified at 49 U.S.C. § 40101 note). Claims alleging injuries suffered at the WTC site, up to and including September 29, 2001, are preempted by the ATSSSA, and must be brought in federal court under the court’s federal question jurisdiction. In re World Trade Ctr. Disaster Site Litig., 270 F. Supp. 2d 357, 374 (S.D.N.Y. 2003), aff'd in part sub nom. In re WTC Disaster Site, 414 F.3d 352 (2d Cir. 2005). Claims for injuries incurred after that date are not preempted and must therefore be brought as state law claims, either in state court or in federal court under the court’s diversity of citizenship jurisdiction. Id. Here, Plaintiff asserts state law claims that occurred after September 29, 2001.

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Jules v. The City of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jules-v-the-city-of-new-york-nysd-2025.