Rivera v. Merritt

CourtDistrict Court, S.D. New York
DecidedAugust 11, 2025
Docket1:24-cv-07882
StatusUnknown

This text of Rivera v. Merritt (Rivera v. Merritt) 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
Rivera v. Merritt, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK REBECA M. RIVERA, Plaintiff, 24-CV-7882 (LTS) -against- ORDER TO AMEND ALENNA MERRITT, Defendant. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who resides in Yonkers, New York, brings this action, pro se, invoking the Court’s federal question jurisdiction. She asserts claims against Alenna Merritt, the Executive Director of Plaintiff’s former employer, a Yonkers-based day care center, Queens Daughter Day Care (“Queens Daughter”). By order dated October 21, 2024, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth below, the Court grants Plaintiff 60 days’ leave to file an amended complaint. 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 of the claims raised. See Fed. R. Civ. P. 12(h)(3). While 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 interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, 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.

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. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. 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. BACKGROUND This action concerns Plaintiff’s employment at Queens Daughter and her eventual firing after her ten-day observation. Plaintiff brings this action against the Executive Director of Queens Daughter, Alenna Merritt. The following facts are drawn from the complaint.1 At some point before September 5, 2023, Merritt interviewed Plaintiff for a teacher’s assistant position. Merritt “told me not to wear tight fitting clothing or legging to work because

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. her husband comes to the job.” (ECF 1, at 10.) Plaintiff states that, at the time of the interview, she “felt uncomfortable and confused when she made the statement about her husband during our interview.” (Id.) Also during the interview, Plaintiff informed Merritt that she wore “a knee brace [d]ue to my disability . . . [and] explain[ed] [that] . . . this would not prevent me from performing my job that I would be hired to do on the second floor of the building.” (Id.) Plaintiff indicates

that she “[n]ever at any moment . . . complain[ed] to Ms. Merritt that the stairs would affect my physical performance.” (Id.) She also indicates that she “was never given a contract or employee protocols.” (Id.) On September 5, 2023, Plaintiff commenced her employment at Queens Daughter as a teacher’s assistant. Within a week of her employment, the teacher of her class quit, and Plaintiff “was the only adult in the Pre-K room with 7-13 toddlers.” (Id.) Plaintiff did not receive any “support from Ms. Merritt.” (Id.) Plaintiff instead relied on her cellphone “to play nursey rhymes and other appropriate school based technology.” (Id.) Plaintiff “was never on my phone for personal reasons.” (Id.) On September 20, 2023, Plaintiff requested a meeting with Merritt, and

Merritt informed Plaintiff that she had “expected more from [Plaintiff] and she thought [Plaintiff] would have done a better job.” (Id. at 11.) During this conversation, Merritt “bec[ame] very irate and her tone of voice was very aggressive.” (Id.) Merritt then informed Plaintiff that she wanted to meet with Plaintiff on September 23, 2023, at “the end of my 10-day observation” when Merritt “planned on firing me.” (Id.) Plaintiff indicates that “after working for Mrs. Merritt I started to have panic attacks. I feel that she defamed my character.” (Id.) Plaintiff states that “[a]s a minority woman I wear a scarf on my head to protect my hair [and that] I would only wear the scarf on my head on my way to work.” (Id.) Plaintiff also states that she “never wore the scarf on my head throughout the day in the school building during business hours.” (Id.) Plaintiff does not state the relief she seeks. DISCUSSION Plaintiff invokes this Court’s federal question jurisdiction as a basis for the Court’s

exercising jurisdiction, but the complaint does not suggest that Plaintiff’s claims against Merritt arise under federal law. Because Plaintiff mentions that (1) as a minority woman, she wears a head scarf, and that (2) sherequires a knee brace, the Court construes the complaint as asserting claims under Title VII of the Civil Rights Act, the Americans with Disabilities Act (“ADA”),42 U.S.C. §1981, and New York State Human Rights Law (“HRL”).Should Plaintiff wish to pursuefurther any claims under any of these statutes, she must allege facts plausibly suggesting that the named defendants violated her statutory rights. A. Antidiscrimination Statutes Proper Defendants Under Title VII and ADA Plaintiff brings this action against Alenna Merritt, the Executive Director of Queens Daughter. Under both Title VII and the ADA, claims may only be brought against anemployer,

not individuals. See Mira v. Kingston, 218 F. Supp. 3d 229, 235 (S.D.N.Y.

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Rivera v. Merritt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-merritt-nysd-2025.