J.M. v. New York State

Summary

The Appellate Division, Third Department affirmed dismissal of an amended complaint challenging the alleged administration and endorsement of SCPA article 17-a guardianships. The court held that Disability Rights New York lacked organizational standing because it failed to establish an injury-in-fact, and that the individual plaintiffs' ADA and Rehabilitation Act claims were time-barred under New York's three-year personal-injury limitations period. The court also declined to apply the continuing violation doctrine and found the equitable tolling argument unpreserved.

Holdings

1. Disability Rights New York lacked organizational standing because it did not demonstrate that its expenditures advocating for individuals affected by SCPA article 17-a guardianships drained its resources beyond its authorized purpose or frustrated that purpose, and therefore failed to establish an injury in fact.
2. The ADA and Rehabilitation Act claims were time-barred because, absent an express federal limitations period, New York's three-year personal-injury limitations period applied and the claims accrued when the individual plaintiffs were placed under SCPA article 17-a guardianships in 2001, 2007, and 2011.
3. The continuing-violation doctrine did not apply because the plaintiffs did not allege use of the Unified Court System's forms within the three years before the action commenced and asserted only generalized claims that failed to identify a discriminatory practice directed at the individual plaintiffs.
4. The equitable-tolling argument was unpreserved because plaintiffs did not raise it before Supreme Court.

Questions Presented

1. Whether Disability Rights New York established organizational standing by showing an injury in fact.
2. Whether the individual plaintiffs' ADA and Rehabilitation Act claims were timely under New York's three-year personal-injury limitations period.
3. Whether the continuing-violation doctrine postponed accrual of the ADA and Rehabilitation Act claims.
4. Whether the plaintiffs preserved their equitable-tolling argument for appellate review.

Disposition

affirmed