Davis v. Carty
1:24-cv-06674
S.D.N.Y.May 16, 2025Background:
- Plaintiff Shianne C. Davis, proceeding pro se, filed an employment discrimination complaint in the Southern District of New York against Beatrice Carty and others.
- The Court, by order dated March 13, 2025, found that Davis’s complaint failed to state a claim upon which relief could be granted and granted her 60 days to amend the complaint.
- Davis requested an extension prior to the expiration of her amendment deadline, seeking more time to file her amended complaint.
- The Court granted Davis a partial extension, directing her to file an amended complaint within 60 days of the May 16, 2025 order.
- The March 13 order highlighted that the only proper defendant in a Title VII action against the United States Postal Service is the Postmaster General and that Title VII preempts related state law claims.
- The Court also ruled that any appeal from the order would not be taken in good faith, denying in forma pauperis status for appeal purposes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to state a claim | Davis contends her complaint alleges discrimination | Not detailed | Court finds original complaint insufficient and grants leave to amend |
| Request for time extension | Davis seeks more time to file an amended complaint | Not opposed | Court grants extension in part; 60 days from new order |
| Proper defendant in Title VII action | Davis names individual as defendant | Not detailed | Only Postmaster General is proper defendant in USPS Title VII actions |
| Preemption of state law by Title VII | Davis asserts state law claims alongside federal | Not detailed | Court reiterates Title VII preempts state law discrimination claims |
| Good faith for appeal | Implicit right to appeal denial | Not detailed | Appeal not taken in good faith; in forma pauperis denied for appeal |
Key Cases Cited
- Coppedge v. United States, 369 U.S. 438 (1962) (defines standard for good faith appeals under in forma pauperis status)
(Note: No other reported cases with formal reporter citations appear in this opinion.)
