Waheed v. Park

CourtDistrict Court, S.D. New York
DecidedApril 14, 2025
Docket1:24-cv-09787
StatusUnknown

This text of Waheed v. Park (Waheed v. Park) 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
Waheed v. Park, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SEHRA WAHEED, Plaintiff, -against- 24-CV-9787 (LTS) MOLLY WASOW PARK; SCOTT FRENCH; THE CITY OF NEW YORK; NEW YORK ORDER OF DISMISSAL CITY DEPARTMENT OF SOCIAL WITH LEAVE TO REPLEAD SERVICES; HUMAN RESOURCES ADMINISTRATION, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action under the court’s federal question jurisdiction, alleging that Defendants violated her rights under state and federal law with respect to administration of various public assistance benefits. Named as Defendants are the City of New York, the New York City Department of Social Services (“DSS”), the New York City Human Resources Administration (“HRA”), HRA Administrator Scott French, and DSS Commissioner Molly Wasow Park. The Court construes the complaint as asserting claims under 42 U.S.C. § 1983 that Defendants violated Plaintiff’s right to procedural due process and her right to the timely processing of applications for the Supplemental Nutrition Assistance Program (“SNAP”) under 7 U.S.C. § 2020(e), as well as claims under New York state law. By order dated January 30, 2025, 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 dismisses the complaint, but grants Plaintiff 30 days’ leave to replead her claims in 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 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 Plaintiff attempts to bring this case as a class action, and much of her lengthy complaint is devoted to describing the City of New York’s administration of various public assistance benefits and how the City’s administration of its benefits programs is harming “thousands of low-income New Yorkers.”1 (ECF 1, at 17.) The following allegations are drawn from the

complaint, which is often repetitive and confusing, and are limited to those facts that directly involve Plaintiff.2 In 2023, Plaintiff fell behind in paying her rent for an apartment unit located at 845 United Nations Plaza in Manhattan. She applied to HRA for a “One Deal One Shot Grant for Rental Arrears to stop eviction and pay back rent or even advanced rent and storage bill” but her request “was completely ignored.” (Id. at 22.) On November 6, 2023, Plaintiff filed her “[f]irst application” for $90,000 for Emergency Safety Net Assistance (“ESNA”). (Id.) On October 26, 2023, Plaintiff submitted her “[s]econd application” for ESNA, seeking $67,500 for a year’s “up front rent.”3 (Id.) Both “Shelter Arrears Repayment Agreements” were “authorized and signed” by HRA employees, and the documents included a note that the application would be “deemed complete” after Plaintiff signed it. (Id.) However, Plaintiff “never received any payments on

either of the applications after [she] signed and set it back with all required documentation.” (Id.) Plaintiff had been paying for storage from 2012 through 2020, and from 2021 through 2022, during which time HRA paid the monthly storage fee directly to the storage company. (Id.

1 As discussed below, because Plaintiff is proceeding pro se and is not attorney, she may not bring a class action in federal court. 2 In addition to the 41-page, single-spaced complaint, on December 19, 2024, Plaintiff filed a request for the court to issue summonses that included an additional 78 pages of exhibits. (ECF 14.) 3 Plaintiff does not explain how her “second” application was submitted before her “first” application. at 22.) When Plaintiff was served with eviction, she rented another storage unit and HRA paid $161.99 a month until August 2023. After August 2023, however, “it went unpaid [and] accumulated [a] late fee on [the] past due amount.” (Id. at 22-23.) When Plaintiff “inquired, [she] was not given accurate information [on] the application and status of payment and never received

any certified notices by mail.” (Id. at 23.) When Plaintiff was evicted from her apartment in December 2023, the movers brought all her belongings to two Manhattan Mini Storage units. Plaintiff “submitted a request for rental assistance and storage bill again as it was accumulated with late unpaid fee since August of 2023 with the total amount past due including late fee for storage was $5,500.” (Id. at 24.) Plaintiff made multiple requests by “submitting Form I-137A,” but nothing was paid by HRA for storage or apartment rent, and, on February 28, 2024, all of Plaintiff’s belongings, which she values at “$439,954,97” were auctioned by the storage facility to satisfy her unpaid bills. (Id.) Plaintiff alleges that she had two HRA fair hearings with respect to her applications for benefits from HRA. In each case, the Administrative Law Judge (“ALJ”) directed HRA to

process Plaintiff’s applications for benefits. Plaintiff alleges that, in each case, HRA has failed to comply the ALJ’s order.

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Bluebook (online)
Waheed v. Park, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waheed-v-park-nysd-2025.