Szlosek v. NYS Office of the Attorney General

District Court, S.D. New York·Decided June 25, 2025·No. 1:24-cv-00897·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK DONNA E. SZLOSEK, Plaintiff, OPINION& ORDER – against – 24 Civ. 897 (ER) NEW YORK STATEOFFICE OF THE ATTORNEY GENERAL, Defendant. RAMOS, D.J.: Donna Szlosek, who proceeds pro se, brought this action against her former employer, the New York State Office of the Attorney General (“OAG”), alleging that she was discriminated against based on her age and disability during her employment. Now before the Court is the OAG’s motion to dismiss. For the reasons set forth below, the motion is GRANTED. I. BACKGROUND A. Factual Background The Court accepts the factual allegations in the complaint as true for purposes of the instant motion. In re Parmalat Securities Litigation, 477 F. Supp. 2d 602, 607 (S.D.N.Y. 2007). Szlosek was employed by the OAG as a paralegal from May 2019 to April 5, 2023, and she claims that her co-workers began bullying hershortly after she started at the job. Doc. 1 at 5. She claims that her supervisor, Wendy Dorival, told her that other paralegals did not like her because she was old, and that the paralegals would intimidate her, throw things at her, and kick her in the back “to the entertainment and viewing” of Dorival. Id. She also alleges that the OAG withheld work and mandatory training from her. Id. Szlosek asserts that she was denied accommodations for her spine condition after she provided letters from two doctors describing her “condition and limits.” Id. at 5, 6. For example, she was given a broken chair with a falling back and opening where her spine needed support. Id. at 5.1 Further, Szlosek was assigned to make multiple trips per day to courts and government agencies, despite the fact that she had difficulty walking, even in extreme weather. Id. She was allegedly required to lift heavy boxes and was subjected to verbal abuse, including being called an “old wrinkled hag,” and was told she needed psychiatric help when she became emotional in response. Id. at 6. Szlosek claims that Mary Clauncy, a Human Resourcesrepresentative, harassed her several times a week and threatened her job when she was out on sick leave after her spine surgery. Id. at 5. She also alleges that the OAG triedto cancel her long-term disability insurance and health insurance after her spine surgery and wanted her to return to workfive days a week in person, even though other employees were required to work in person only one day per week. Id. Szlosek was terminated on April 5, 2023. Id. She alleges the OAG fired her because she was not able to return to the work within the time frame the OAG required due to her slow recovery from her spine surgery. Id. B. Procedural Background Szlosek filed a charge with the U.S. Equal Employment Opportunity Commission (“EEOC”)in approximately August 2023 and received a notice of right to sue on November 14, 2023. Doc. 1 at 6. Szlosek subsequently filed this complaint on February 6, 2024. Doc. 1 at 7. Szlosek asserts claims of age discrimination pursuant to the Age

1In her Amended Charge of Discrimination filed with the New York State Division of Human Rights and EEOC, Szlosek alleges that she was “refused the simplest of accommodations for [her] disability.” Doc. 1- 1 at 2. For example, she claims she submitted a request for a chair that provided more support to Mary Clauncy, who handles accommodations. Clauncy informed her that it is not easy for the office to get special chairs and that she would have to deal with what she had. Szlosek therefore purchased a cushion with her own funds that was stolen when she was not at her desk. Doc. 1-1 at 2. The Court offers no opinion as to whether Szlosek could bring successful failure to accommodate claims pursuant to Section 504 under the Rehabilitation Act, which applies to government entities that have waived Eleventh Amendment immunity through the receipt of federal funds. See Degrafinreid v. Ricks, 417 F. Supp. 2d 403, 413–15 (S.D.N.Y.), on reconsideration, 452 F. Supp. 2d 328 (S.D.N.Y. 2006). Discrimination in Employment Act (“ADEA”),and disability discrimination under Title I of the Americans with Disability Act (“ADA”). She also alleges that the OAG violated the New York State Human Rights Law (“NYSHR”) and New York City Human Rights Law (“NYCHR”). On January 31, 2025, the OAG moved to dismiss the complaint pursuant to Federal Rule of Civil Procedure 12(b)(1), arguing that it is entitled to sovereign immunity under the Eleventh Amendment to the U.S. Constitution. Doc. 34. Szlosek filed an opposition on February 25, 2025, in which she requested the Court grant her leave to amend the complaint. Doc. 38. The OAG replied to Szlosek’s response on March 6, 2025, further requesting that the Court to grant the motion to dismiss, with prejudice. Doc. 39. II. LEGAL STANDARDS A. Rule 12(b)(1) Motion to Dismiss: Subject Matter Jurisdiction Pursuant to Rule 12(b)(1), the Court must dismiss a case for lack of subject matter jurisdiction if the Court “lacks the statutory or constitutional power to adjudicate it.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). The party asserting subject matter jurisdiction carries the burden of establishing, by a preponderance of the evidence, that jurisdiction exists. Morrison v. National Australia Bank Ltd., 547 F.3d 167, 170 (2d Cir. 2008) (quoting Makarova, 201 F.3d at 113). On a Rule 12(b)(1) motion challenging the district court’s subject matter jurisdiction, evidence outside of the pleadings may be considered by the court to resolve the disputed jurisdictional fact issues. Zappia Middle East Construction Company v. Emirate of Abu Dhabi, 215 F.3d 247, 253 (2d Cir. 2000) (internal citation omitted); see also Morrison, 547 F.3d at 170 (citing Makarova, 201 F.3d at 113). When evaluating a motion to dismiss for lack of subject matter jurisdiction, the court accepts all material factual allegations in the complaint as true but does not necessarily draw inferences from the complaint favorable to the plaintiff. J.S. ex rel. N.S. v. Attica Central School, 386 F.3d 107, 110 (2d Cir. 2004) (citing Shipping Financial Services Corporationv. Drakos, 140F.3d 129, 131 (2d Cir. 1998)). B. Pro Se Litigants The courts should interpret pro se litigants’pleadings and other filings to raise the strongest claims they suggest. Sharikov v. Philips Medical System MR, Inc., 103 F.4th 159, 166(2d Cir. 2024). In general, “[a] pro se complaint ‘should not be dismissed without the Court granting leave to amend at least once when a liberal reading of the complaint gives any indication that a valid claim might be stated.’” Chavis v. Chappius, 618 F.3d 162, 170 (2d Cir. 2010)(alterations adopted)(quoting Branum v. Clark, 927 F.2d 698, 705 (2d Cir. 1991)). However, notwithstanding the liberal pleading standards afforded pro se litigants, federal courts are courts of limited jurisdiction and may not preside over cases if they lack subjectmatter jurisdiction. Lewis v. City of New York, 762 F. Supp. 3d 290, 301 (S.D.N.Y. 2025)(quoting Torres v. Blackstone Group, No. 18 Civ. 6434 (RA), 2019 WL 4194496, at *2 (S.D.N.Y. Sept. 3, 2019) (internal quotation marks omitted), aff’d, 836 F.

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