Wade v. Broadnax

CourtDistrict Court, S.D. New York
DecidedJune 21, 2024
Docket1:24-cv-03463
StatusUnknown

This text of Wade v. Broadnax (Wade v. Broadnax) 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
Wade v. Broadnax, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CARLENE WADE, Plaintiff, -against- 24-CV-3463 (LTS) KEISHA BROADNAX; LUIS MAHER; ORDER TO AMEND RICHARD WATSON; MICHAEL KALISH; JUDITH GIBERSTON, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is proceeding pro se, brings this action under the Americans with Disabilities Act of 1990 (“ADA”), 42 U.S.C. §§ 12112-12117, and the Family and Medical Leave Act of 1993 (“FMLA”). By order dated May 8, 2024, the Court granted Plaintiff’s request to proceed in forma pauperis, that is, without prepayment of fees. For the reasons set forth below, the Court grants Plaintiff leave to file an amended complaint within 60 days of the date of this order. STANDARD OF REVIEW The Court must dismiss an in forma pauperis 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 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 The only facts alleged in Plaintiff’s complaint are the following: Keisha Broadnax, Luis Maher, Richard Watson, Judith Giberstone & Michael Kalish retaliated and terminated my employment.

(ECF 1 at 5.) These same individuals are the named defendants.

On the form complaint for employment discrimination actions, Plaintiff checks off that she suffered retaliation and that her employment was terminated, in violation of the ADA and FMLA. (Id. at 4-5.) Plaintiff filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC) on September 23, 2024, and the EEOC issued a notice of right to sue on February 5, 2024. (Id. at 6.) Plaintiff seeks damages and an order directing that her employer, who is not specified, reemploy her. DISCUSSION A. ADA Claim “The ADA prohibits discrimination against a ‘qualified individual on the basis of disability’ in the ‘terms, conditions, and privileges of employment.’” Kinneary v. City of New

York, 601 F.3d 151, 155 (2d Cir. 2010) (quoting 42 U.S.C. § 12112(a)). A person is disabled under the ADA if the person has “a physical or mental impairment that substantially limits one or more major life activities.” 42 U.S.C. § 12102(1)(A). The ADA prohibits an employer from either mistreating an individual because of the individual’s protected characteristics, Patane v. Clark, 508 F.3d 106, 112 (2d Cir. 2007), or retaliating against an employee who has opposed any practice made unlawful by those statutes, see Crawford v. Metro. Gov’t, 555 U.S. 271, 276 (2009) (holding that conduct is protected when it “confront[s],” “resist[s],” or “withstand[s]” unlawful actions). At the pleading stage, a plaintiff must allege “facts that directly show discrimination or facts that indirectly show discrimination by giving rise to a plausible inference

of discrimination.” Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72, 87 (2d Cir. 2015). Mistreatment at work that occurs for a reason other than an employee’s protected characteristic or opposition to unlawful conduct is not actionable under the ADA. See Chukwuka v. City of New York, 513 F. App’x 34, 36 (2d Cir. 2013) (quoting Brown v. Henderson, 257 F.3d 246, 252 (2d Cir. 2001)). Here, Plaintiff has not named her employer as a defendant. She names only individuals, but individuals are not proper defendants for an ADA claim. See, e.g., Oren v. Franklin Square Pub. Libr., No. 20-CV-0425, 2023 WL 5279384, at *9 (E.D.N.Y. Jan. 31, 2023) (“[T]here is no individual liability, under . . . the ADA.”).1 Plaintiff has also not pleaded any facts indicating that she has a disability. Plaintiff alleges that she was retaliated against and her employment was terminated, but she has not explained what happened that could give rise to an inference that her disability motivated those adverse actions or played any role. Plaintiff thus fails to allege facts

sufficient to state a claim under the ADA on which relief can be granted. B. FMLA Claim The FMLA allows covered employees to take up to 12 weeks of unpaid leave per year to care for the employee’s own serious health condition or to care for a parent, spouse, or child who has a serious health condition. Higgins v. NYP Holdings, Inc., 836 F. Supp. 2d 182, 193 (S.D.N.Y. 2011) (citing 29 U.S.C. § 2612). The Second Circuit has recognized two types of FMLA claims, claims of interference and claims of retaliation. See Smith v.

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Related

Kinneary v. City of New York
601 F.3d 151 (Second Circuit, 2010)
Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Peter Potenza, Clifford Aversano v. City of New York
365 F.3d 165 (Second Circuit, 2004)
Chukwuka v. City of New York
513 F. App'x 34 (Second Circuit, 2013)
Patane v. Clark
508 F.3d 106 (Second Circuit, 2007)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Smith v. Westchester County
769 F. Supp. 2d 448 (S.D. New York, 2011)
Graziadio v. Culinary Institute of America
817 F.3d 415 (Second Circuit, 2016)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)
Vega v. Hempstead Union Free School District
801 F.3d 72 (Second Circuit, 2015)
Higgins v. NYP Holdings, Inc.
836 F. Supp. 2d 182 (S.D. New York, 2011)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)

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Wade v. Broadnax, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wade-v-broadnax-nysd-2024.