Logan v. Albany City School District

CourtDistrict Court, N.D. New York
DecidedAugust 27, 2025
Docket1:24-cv-00887
StatusUnknown

This text of Logan v. Albany City School District (Logan v. Albany City School District) 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
Logan v. Albany City School District, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

LASHANDA LOGAN,

Plaintiff,

v. 1:24-cv-00887 (AMN/PJE)

ALBANY CITY SCHOOL DISTRICT,

Defendant.

APPEARANCES: OF COUNSEL:

BERLINGIERI LAW PLLC CHRISTOPHER BERLINGIERI, ESQ. 244 Fifth Avenue – Suite F276 New York, New York 10001 Attorneys for Plaintiff

JOHNSON & LAWS, LLC GREGG TYLER JOHNSON, ESQ. 646 Plank Road – Suit 205 Clifton Park, New York 12065 Attorneys for Defendant Hon. Anne M. Nardacci, United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION On July 17, 2024, Plaintiff Lashanda Logan (“Plaintiff”) commenced this action pursuant to Title I of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. (“ADA”), the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq. (“FMLA”), and the New York State Human Rights Law, N.Y. Exec. Law § 290 et seq. (“NYSHRL”), asserting claims arising out of her employment with the Albany City School District (“Defendant”). Dkt. No. 1 (“Complaint”). Presently before the Court is Defendant’s motion to dismiss the Complaint pursuant to Rule 12 of the Federal Rules of Civil Procedure (“Rule 12”). Dkt. No. 8 (“Motion”). Plaintiff partially opposes the Motion, Dkt. No. 10, and Defendant filed reply papers in further support, Dkt. No. 11. For the reasons set forth below, the Motion is granted and the Complaint is dismissed. II. BACKGROUND Unless otherwise noted, the following facts are drawn from the Complaint, its attachments, or materials it incorporates by reference, and are assumed to be true for purposes of ruling on the

Motion, see Div. 1181 Amalgamated Transit Union-N.Y. Emps. Pension Fund v. N.Y.C. Dep’t of Educ., 9 F.4th 91, 94 (2d Cir. 2021) (per curiam), or are otherwise matters of public record, see Williams v. N.Y.C. Hous. Auth., 816 F. App’x 532, 534 (2d Cir. 2020). A. The Parties Plaintiff alleges that she has an unspecified learning disability. Dkt. No. 1 at ¶¶ 14-15. Defendant is a school district in Albany, where Plaintiff resides. Id. at ¶¶ 10-11. B. Plaintiff’s Employment In or around August 2019, Plaintiff began working as a temporary employee at Defendant. Id. at ¶ 13. She worked as a clerk at Albany High School. Id. She alleges that, at the time of her

hire, she was exempt from a Civil Service examination requirement for her position because of her learning disability. Id. at ¶ 17. “In or around 2021, Defendants [sic] hired Plaintiff full time.” Id. at ¶ 18. In or around September 2022, Plaintiff “learned that [her] learning disability was being discussed by coworkers as a joke.” Id. at ¶ 19. Plaintiff alleges that one coworker also made derogatory remarks directly to her regarding her learning disability. Id. at ¶¶ 20-22. On September 21, 2022, Plaintiff reported that coworker’s alleged remarks to several administrators at Defendant as well as a union president. Id. at ¶¶ 23-25. Plaintiff “requested a transfer to another workplace location as a reasonable accommodation.” Id. at ¶ 26. Plaintiff alleges that she faced workplace harassment “[l]eading up to her transfer request.” Id. at ¶ 27. In or around October 2022, Plaintiff suffered a stroke. Id. at ¶ 28. Plaintiff “went on FMLA leave from October 2022” as a result. Id. at ¶ 29. In November 2022, Plaintiff alleges that Defendant filed false disciplinary charges against her and issued a written warning. Id. at ¶¶ 30-32. Plaintiff alleges that Defendant’s representatives

wanted to meet with her and the union regarding the discipline on November 15, 2022, but that they notified her only five days before the scheduled meeting and did not reschedule the meeting as she requested. Id. at ¶ 33. In April 2023, Defendant granted Plaintiff “intermittent FMLA leave,” which Plaintiff took “when needed.” Id. at ¶¶ 34-35. On August 9, 2023, Defendant sent Plaintiff a letter stating in part that: [Y]ou have refused to take the examination for the title in which you were appointed on a provisional basis. In late April 2023, the City School District of Albany Human Resources Division and the City of Albany Office of Human Resources repeatedly advised you to register for the required examination, which is given on a continuous basis. According to Civil Service Law Section 65 and Local Civil Service Rule XVII which govern provisional appointments in the competitive class, you must be removed from the Clerk Typist title immediately as there is an active eligible list. We will take action at the August 24, 2023 Board meeting to terminate your employment, effective immediately. If you wish to resign instead, please do so in writing by August 18, 2023.

Id. at ¶ 40; see also Dkt. No. 8-4.

Plaintiff alleges that she “never refused to take the Civil Service exam.” Dkt. No. 1 at ¶¶ 51, 54. Plaintiff further alleges that she “would be willing to take the exam with reasonable accommodations,” but that “Defendant failed to accommodate Plaintiff so that she could take the exam.” Id. at ¶¶ 52, 55. On August 13, 2023, Plaintiff filed a charge of discrimination (“Charge”) with the United States Equal Employment Opportunity Commission (“EEOC”). Id. at ¶¶ 5, 36; see also Dkt. No. 8-2. The Charge contained the following particulars: I am a qualified individual with a disability, and I was hired by the Respondent, Albany City School District, in approximately August 2019. My current position with the Respondent is Clerk. I believe I have been treated adversely by the Respondent because of my disability. I asked for a reasonable accommodation in approximately September 2022 to be moved to a different building because my disability was being discussed as a joke amongst coworkers. Before, and leading up to my request, I faced difficulties in successfully performing my job duties such as being locked out of the computer systems, payroll issues, and was later faced with disciplinary measures in approximately November 2022. I believe I have faced harassment and have been treated unfavorably because of my disability and for requesting a reasonable accommodation, in willful violation of Title I of the Americans with Disabilities Act of 1990, as amended.

Dkt. No. 8-2 at 2.1 Plaintiff’s signature on the Charge includes “Esq.” Id. On August 23, 2023, Defendant terminated Plaintiff’s employment. Dkt. No. 1 at ¶ 41. Plaintiff alleges that she “was still on FMLA” sometime “[i]n August 2023.” Id. at ¶¶ 37, 41. On April 18, 2024, the EEOC issued Plaintiff a notice of right to sue. Id. at ¶ 6; see also Dkt. No. 1-1. C. Plaintiff’s Legal Claims Based on Plaintiff’s factual allegations, she asserts six claims in the Complaint: (i) discrimination and retaliation under the ADA, Dkt. No. 1 at ¶¶ 58-65; (ii) interference and retaliation under the FMLA, id. at ¶¶ 66-74; and (iii) discrimination and retaliation under the NYSHRL, id. at ¶¶ 75-81. III. STANDARD OF REVIEW A motion to dismiss for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) is properly granted “when the court lacks statutory or constitutional authority to adjudicate it.” Cayuga Indian Nation of New York v. Vill. of Union Springs, 293 F. Supp. 2d 183, 187 (N.D.N.Y.

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Bluebook (online)
Logan v. Albany City School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/logan-v-albany-city-school-district-nynd-2025.