Washington v. DHS Department of Homeless Services

CourtDistrict Court, S.D. New York
DecidedJanuary 2, 2025
Docket1:24-cv-05042
StatusUnknown

This text of Washington v. DHS Department of Homeless Services (Washington v. DHS Department of Homeless Services) 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
Washington v. DHS Department of Homeless Services, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SANDRA A. WASHINGTON, Plaintiff, 24-CV-5042 (LTS) -against- ORDER TO AMEND NYC DHS; WIN SHELTER, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action invoking the Court’s federal question jurisdiction. By order dated November 21, 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 portion thereof, 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. 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, 474-75 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). BACKGROUND The following facts are drawn from the complaint.1 Plaintiff alleges that her claims arose between February 2020 and May 2024, at the WIN homeless shelter. She alleges that there were “very dirty and unsanitary condition[s]” at the shelter, and that “the drinking water at the time was mixed with other toxic substance[s].” (ECF 1, at 10.)

Moreover, Plaintiff refers to “Physical and Mental Abuse of an individual residing in a shelter,” allegedly in violation of “State Abuse Laws.” (Id., at 10.) She attaches a document on which she wrote, “09/25/23 called police physically threatened.” (Id., at 12.) Plaintiff also states the following: I observed the Rights of other homeless individuals beings violated in the time I occupied the Shelter and was forced to call the Authorities. However, nothing has been done and these violation are still ongoing.

(Id., at 10.)

Plaintiff also contends that the New York City Department of Homeless Services (DHS) violated local “DHS guidelines” and federal “Disability Acts” by failing to secure permanent housing for her, as a “Home Bound Individual,” “in a timely manner.” (Id., at 8.) Plaintiff was awarded a housing voucher, but it did not provide “reasonable and adequate funding for the monthly rent of an apartment . . . in New York City,” and she was therefore “unable to get an apartment.” (Id., at 9.) She told staff at WIN about this but “no one did anything to facilitate the additional funds or monies needed. . . .” (Id.) WIN and DHS failed to provide “adequate services needed for a person with a disability to obtain housing.” (Id., at 10.) DHS violated the Fair

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. Housing Act “in that [Plaintiff] was not treated Fairly for a HOMELESS person in this city”; she was denied the “basic right” to housing. (Id.) Plaintiff brings this suit against DHS and WIN, invoking the following: “Human Right Act of the Constitution, Title VIII 1968 Disabled DHS -118A Health Dept 1926 55.” (Id., at 2.)

Plaintiff seeks “permanent housing” and $9.2 million in monetary compensation. She also asks the Court “to hold DHS accountable for violating the Constitution” and hold WIN staff accountable. (Id., at 6.) DISCUSSION A. New York City Department of Homeless Services Federal courts look to the law of the State to determine whether an entity has the capacity to be sued. See Fed. R. Civ. P. 17(b). Under the New York City Charter, the New York City DHS, as an agency of the City of New York, cannot be sued in the name of the agency. N.Y. City Charter ch. 17, § 396 (“[A]ll actions and proceedings for the recovery of penalties for the violation of any law shall be brought in the name of the city of New York and not in that of any agency, except where otherwise provided by law.”); Jenkins v. City of New York, 478 F.3d 76, 93

n.19 (2d Cir. 2007); see also Emerson v. City of New York, 740 F. Supp. 2d 385, 396 (S.D.N.Y. 2010) (“[A] plaintiff is generally prohibited from suing a municipal agency.”). Plaintiff’s claims against DHS must therefore be dismissed because DHS lacks the capacity to be sued. Because Plaintiff proceeds pro se, the Court grants Plaintiff leave to file an amended complaint. See Hill v. Curcione, 657 F.3d 116, 123-24 (2d Cir. 2011) (holding that district courts should grant a self-represented plaintiff an opportunity to amend a complaint to cure its defects, unless amendment would be futile). If Plaintiff chooses to file an amended complaint and names the City of New York as a defendant for her claims about the actions of the DHS, the Court notes that, in order to state a claim under Section 1983, it is not enough for the plaintiff to allege that one of the municipality’s employees or agents engaged in some wrongdoing. The plaintiff must show that the municipality itself caused the violation of the plaintiff’s rights. See Connick v. Thompson, 563 U.S. 51, 60 (2011) (“A municipality or other local government may be liable under . . . section [1983] if the governmental body itself ‘subjects’ a person to a deprivation of

rights or ‘causes’ a person ‘to be subjected’ to such deprivation.” (quoting Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 692 (1978)). In other words, to state a Section 1983 claim against the City of New York, the plaintiff must allege facts showing (1) the existence of a municipal policy, custom, or practice, and (2) that the policy, custom, or practice caused the violation of the plaintiff’s constitutional rights. See Jones v. Town of East Haven, 691 F.3d 72, 80 (2d Cir. 2012). If Plaintiff seeks to assert a claim based on a policy, custom, or practice of the DHS, she must name the City of New York as a defendant in an amended complaint, identify the policy, custom, or practice at issue, and plead facts showing that the policy, custom, or practice caused a violation of his constitutional rights.2

2 The Court further notes that the government does not have a general duty arising under the U.S. Constitution to protect an individual from harm, where the government is not holding the person in custody. See DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189, 195- 96 (1989). Nor does the Constitution guarantee housing quality. See Lindsey v. Normet, 405 U.S. 56, 74 (1972) (“We do not denigrate the importance of decent, safe, and sanitary housing.

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Washington v. DHS Department of Homeless Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-dhs-department-of-homeless-services-nysd-2025.