Tyrone Houston, a/k/a Tyrone Black v. Eric Adams, et al.

District Court, S.D. New York·Decided March 17, 2026·No. 1:25-cv-06494·Unknown

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SoC eT AELY FILED TYRONE HOUSTON, a/k/a TYRONE BLACK, DATE FILED: _ 3/17/2026 Plaintiff, 25-CV-06494 (MMG) -against- MEMORANDUM ERIC ADAMS, et al., OPINION AND ORDER Defendants.

MARGARET M. GARNETT, United States District Judge: Plaintiff, who is proceeding pro se and in forma pauperis (“IFP”), brings this action under 42 U.S.C. § 1983, alleging that various New York City and New York State agencies and officials violated his federal constitutional rights by denying him certain public benefits, including medical aid, food assistance, and housing. See Dkt. No. 20. Named as Defendants are: (1) former New York City Mayor Eric Adams (““Adams”); (2) the City of New York; (3) New York City Human Resources Administration (“HRA”) Commissioner Molly Wasow Park (“Park”); (4) HRA Administrator Scott French (“French”); (5) New York Governor Kathy Hochul (“Hochul”); (6) New York State Office of Temporary and Disability Assistance (“OTDA”) Commissioner Barbara C. Guinn (“Guinn”); (7) OTDA Associate Deputy Commissioner Samuel L. Spitzberg (“Spitzberg”); (8) OTDA Executive Deputy Commissioner Rajni Chawla (“Chawla”); (9) New York City Homeless Services Administrator Joslyn Carter (“Carter”), (10) a John Doe supervisor at Dyckman Job Center who worked on January 6, 2023, from 8:30AM to 4:00PM (the “HRA John Doe”); (11) the John/Jane Doe “OTDA Supervisors responsible for Plaintiff's state disability payments from 1/1/24 thru 1/1/25” (the “OTDA John Does”) (12) New York State of Health; and (13) Health First Health Care. See Dkt. No. 20 at 1- 2, 5-7. In addition to monetary relief, Plaintiff seeks a temporary restraining order and

preliminary injunction ordering the Defendants to restore his benefits and to provide him necessary medical care. See Dkt. Nos. 12, 22, 24. For the reasons that follow, Plaintiff’s motions for emergency relief are DENIED, and his claims against Guinn, Park, French, Carter, Spitzberg, Chawla, the OTDA John Does, New York

State of Health, and Health First Health Care are DISMISSED. The Court directs service on Adams, Hochul, and the City of New York; and directs the City of New York to assist Plaintiff in identifying the HRA John Doe. BACKGROUND I. RELEVANT FACTS1 0F Plaintiff is a “New York state parolee” on lifetime supervised release who suffers from glaucoma, COPD, asthma, hypertension, and arthritis. Dkt. No. 20 at 5. On January 5, 2023, he was released from the custody of the New York Department of Corrections and Community Supervision (“DOCCS”) and placed under parole supervision at the Edgecombe Residential Treatment Facility (“Edgecombe”), a transitional housing program for parolees in Manhattan. Dkt. No. 16 at 2; Dkt. No. 20 at 5. The day after his release, Plaintiff went to the Dyckman Job Center, an HRA site in Manhattan, and applied for: (1) “emergency medical treatment based on Plaintiff’s glaucoma, COPD, asthma, hypertension and chronic arthritis pains;” (2) “emergency housing assistance to address Plaintiff’s status in transitional housing and risk of displacement;” and (3) cash

1 These facts derive from Plaintiff’s amended complaints, Dkt. Nos. 4 (“First Amended Complaint”) & 20 (“Second Amended Complaint”), as well as the various submissions in support of Plaintiff’s motions for emergency relief, Dkt. Nos. 13, 16–18, 22–27. Plaintiff’s submissions contain typographical errors and use nonstandard grammar, spelling, punctuation, and capitalization. In quoting the submissions, the Court will conform the capitalization to accepted standards but will otherwise reproduce Plaintiff’s statements as written. assistance for essential survival needs.” Dkt. No. 20 at 8. He alleges that the HRA John Doe informed him that the “Governor of New York and Mayor of New York City has issued directives instructing HRA staff to prioritize non-citizens and illegal aliens over American citizens when processing applications for emergency services.” Id. at 9. Moreover, the HRA

John Doe allegedly stated that the HRA was providing “the exact same services (emergency medical, housing and cash) to illegal healthy individuals and non-citizens who had applied after Plaintiff.” Id. Plaintiff alleges that he was denied emergency medical treatment and housing, id. at 11, and appears to allege that he began receiving cash assistance in the form of Supplemental Nutrition Assistance Program (“SNAP”) and New York State Supplement Program (“SSP”) benefits, but that those benefits were later unlawfully reduced. Id. at 10, 13, 15. Specifically, between January 2024 and January 2025, “Defendants Guinn, Park, French, NYS of Health and Health First” allegedly “stole $64.00 out of $78.00 out of Plaintiff’s state supplemental program (a loss over 90%).” Id. at 13. Relatedly, he alleges that on April 17, 2023, March 20, 2024, and

October 17, 2025, he appeared “before fair hearings officers, representing defendants Guinn, Park, Jane/John Doe (OTDA Supervisor for 1/1/24 thru 1/1/25), Carter and French, and was denied housing, reasonable SNAP to confirm with medical and beliefs to eat low-sodium and non-preservations food.” Id. at 9. Plaintiff attributes the denial and reduction of his benefits to unlawful discrimination by Defendants. Based on the HRA John Doe’s comments regarding a purported government bias favoring unlawful immigrants, Plaintiff alleges that “Eric Adams, Kathy Hochul and the City of New York entered into a meeting of the minds to enact policies that prioritize non-citizen over American citizen for the distribution of finite HRA emergency funds.” Id. at 12. He asserts that “this prioritization was carried out under the umbrella of the ‘open broader policy under Biden/Harris administration’ and other municipal policies which Plaintiff alleges are being used to rob and embezzle funds, specifically by reducing Plaintiff’s SSP disability and SNAP benefits to fund services for non-citizens.” Id. at 10. He alleges that the $64 “stolen” from his cash

benefits was used to pay for “awarding illegal aliens $350.00 per week debt cash card, $1,000 SNAP monthly, emergency housing and Medicaid cards.” Id. at 13. Further, he alleges that Defendants Guinn, Park, French, NYS of Health, and Health First “were the ‘operational arms’ of the conspiracy” who “received these top-down instructions and knowingly executed the reduction in benefits.” Id. at 13–14. He maintains that “[t]his conspiracy was motivated by a class based, discriminatory animus, as evidenced by HRA’s public admission that resources are being diverted from America-born disabled citizens to non-citizens.” Id. at 15. Besides the alleged discrimination, Plaintiff also alleges a lack of due process in connection with his loss of benefits. Id. at 14. He states he “was given no notice or aid to continue about 11/2024 reclassification of SNAP and Medicaid” and that Defendants

“knowingly executed the reduction in benefits without due process (notice of hearing on housing denial).” Id. Separately, Plaintiff alleges that “Defendant Eric Adams and the City of New York have maintained a policy of unlawful retention exceeding three (3) years, despite Plaintiff’s 1/5/23 release from prison.” Dkt. No. 16 at 3. This allegation is apparently in reference to Plaintiff’s residence in transitional housing at Edgecombe since being paroled. During that time, Plaintiff allegedly suffered the “denial of glaucoma eye drops for 3+ years, denial of asthma, COPD, hypertension, arthritis medications and care,” which resulted from a “systemic failure of NYS DOCCS and NYC to track and have HRA/OTDA supervisors submit the proper housing paperwork for medically dependent parolee.” Id. at 1, 3.

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Tyrone Houston, a/k/a Tyrone Black v. Eric Adams, et al., (S.D.N.Y. 2026).

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