Lydia Chais v. City University of New York (CUNY), et al.

CourtDistrict Court, E.D. New York
DecidedJune 30, 2026
Docket1:25-cv-05104
StatusUnknown

This text of Lydia Chais v. City University of New York (CUNY), et al. (Lydia Chais v. City University of New York (CUNY), et al.) 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
Lydia Chais v. City University of New York (CUNY), et al., (E.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

LYDIA CHAIS

Plaintiff, v. MEMORANDUM & ORDER 25-CV-05104 (HG) (RML) CITY UNIVERSITY OF NEW YORK (CUNY), et al.,

Defendants.

HECTOR GONZALEZ, United States District Judge: The Court previously granted pro se Plaintiff Lydia Chais’s request to proceed in forma pauperis, dismissed her complaint without prejudice, and granted her leave to amend the complaint. See ECF No. 4 (Memorandum & Order).1 Plaintiff subsequently filed an amended complaint, asserting claims under 42 U.S.C. § 1983 (“Section 1983”), the Americans with Disabilities Act (“ADA”), the Rehabilitation Act of 1973 (“Rehabilitation Act”), and the Fair Labor Standards Act (“FLSA”). See ECF No. 5 (Amended Complaint; “AC”). Specifically, Plaintiff alleges discrimination, retaliation, wage withholding, and due process violations by Defendants Kingsborough Community College (“KCC”), the City University of New York (“CUNY”), and District Council 37 (“DC 37”), among other Defendants. See id. For the reasons set forth below, Plaintiff’s Amended Complaint is DISMISSED pursuant to 28 U.S.C. § 1915(e)(2)(B).

1 Unless otherwise indicated, when quoting cases and Plaintiff’s amended complaint, the Court omits all internal quotation marks, alteration marks, emphases, footnotes, and citations. The Court refers to the pages assigned by the Electronic Case Files system (“ECF”). BACKGROUND2 From March to September 2024, Plaintiff was employed as a College Assistant Writing Tutor at KCC’s Learning Center (“KLC”). AC at 8 ¶¶ 1–2. During Plaintiff’s employment, Defendants Michael Weisenfeld, KLC Director, and Mohammed Riyad, KLC Associate

Director, allegedly instructed Plaintiff to reduce the number of work hours she recorded on her timesheets, or in other words, to falsify her timesheets. Id. at 8 ¶¶ 3–4. After Plaintiff refused, Defendants purportedly retaliated against her by sending “harassing emails copied to administrators and union contacts, falsely implying [her] misconduct,” withholding her wages, reducing her hours, id. ¶¶ 5–6, 8, and denying her leave, id. at 14 ¶ 3. On September 13, 2024, Plaintiff “was constructively dismissed.” Id. at 11 ¶ 16. Plaintiff alleges that she has a “documented disability,” and although she disclosed the disability and her related funding3 to her employer, Defendants failed to engage in the required ADA process. AC at 8 ¶¶ 9–10. Plaintiff allegedly notified Defendants and KCC employees Beth Douglas, Legal Counsel; Gila Rohr, Human Resources (“HR”) Director; Sharon Warren

Cook, Provost; and Alex Kisel, Central HR Administrator, of the ADA violations, retaliation, and wage issues, but they failed to take action. Id. at 8–9 ¶ 11A. Moreover, Plaintiff asserts that at a 2025 hearing, Defendants Rohr and Riyad withheld information about her disability from the Administrative Law Judge, which led to denial of her unemployment benefits and imposition of an overpayment assessment. Id. at 9 ¶ 11B. Finally, Plaintiff alleges that DC 37 ignored her

2 The Court “recite[s] the substance of the allegations as if they represented true facts, with the understanding that these are not findings of the [C]ourt, as [I] have no way of knowing at this stage what are the true facts.” In re Hain Celestial Grp., Inc. Sec. Litig., 20 F.4th 131, 133 (2d Cir. 2021). 3 Plaintiff receives “ACCES[]-VR funding through the state vocational-rehabilitation program.” AC at 8 ¶ 9. request for representation at that hearing, id. at 10 ¶ 12, and took retaliatory actions against her by supporting a Guardian ad Litem (“GAL”) filing that lacked a medical basis and by referring her to Adult Protective Services, id. at 12 ¶ 18. Plaintiff further alleges that she submitted several letters to Defendants. Namely, she

asserts that she sent a “Retaliation and Demand Letter” to Riyad in September 2024. AC at 10 ¶ 13, and demand letters to CUNY Chancellor Félix V. Matos Rodríguez on April 8, 2025, and May 4, 2025, in which she reported FLSA violations, id. at 3–4 ¶ 6. Plaintiff alleges that, despite these letters, no action was taken. See id. at 3 ¶¶ 6, 10 ¶ 13. After Plaintiff was “constructively dismissed” from KCC on September 13, 2024, id. at 11 ¶ 16, she filed a discrimination charge with the Equal Employment Opportunity Commission (“EEOC”) and received a right-to-sue letter on December 1, 2025, see ECF No. 7 (Right-To-Sue Letter), approximately three months after she commenced this suit. LEGAL STANDARD A complaint must plead “enough facts to state a claim to relief that is plausible on its

face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Matson v. Bd. of Educ., 631 F.3d 57, 63 (2d Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Although all allegations contained in the complaint are assumed to be true, this tenet is “inapplicable to legal conclusions.” Iqbal, 556 U.S. at 678. Though courts are required to hold pro se pleadings to “less stringent standards than formal pleadings drafted by lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam), pro se plaintiffs still must comply with Rule 8, Harnage v. Lightner, 916 F.3d 138, 141 (2d Cir. 2019). While “detailed factual allegations are not required,” Twombly, 550 U.S. at 678, “[i]t is not enough to say that the defendant harmed me; the claim must include factual details that, if true, would show that the defendant broke the law” and is responsible for the harm to the plaintiff, Ramjas v. Wilknowski, No. 25-cv-3289, 2025 WL 1787168, at *1 (E.D.N.Y. June 27,

2025) (quoting Iqbal, 556 U.S. at 678). To satisfy this standard, the complaint must, at a minimum, “disclose sufficient information to permit the defendant to have a fair understanding of what the plaintiff is complaining about and to know whether there is a legal basis for recovery.” Kittay v. Kornstein, 230 F.3d 531, 541 (2d Cir. 2000). In other words, Rule 8 “merely requires that any complaint be simple, direct and concise.” Turner v. Cnty. of Suffolk, 955 F. Supp. 175, 176 (E.D.N.Y. 1997). Finally, under 28 U.S.C. § 1915(e)(2)(B), a district court shall dismiss an in forma pauperis action that “(i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.” DISCUSSION

I. Plaintiff Fails to Comply with Rule 8 As an initial matter, the Amended Complaint fails to comply with Rule 8’s requirement that Plaintiff provide a “short and plain” statement of her claims against Defendants “to permit [them] to have a fair understanding of what [P]laintiff is complaining about and to know whether there is a legal basis for recovery.” Harnage, 916 F.3d at 141. Under Rule 8, a pro se complaint may be dismissed if it “is so confused, ambiguous, vague, or otherwise unintelligible that its true substance, if any, is well disguised.” Salahuddin v. Cuomo, 861 F.2d 40, 42 (2d Cir. 1988).

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