Golden v. Verizon New York, Inc.

Summary

The Eastern District of New York granted Verizon New York, Inc.’s Rule 12(b)(6) motion to dismiss Timothy J. Golden’s breach-of-contract claims arising from alleged violations of collective bargaining agreements concerning disability accommodation. The court held that the claims were preempted by Section 301 of the Labor Management Relations Act and barred by res judicata based on Golden’s prior federal action. The court also concluded that any claim under Section 503 of the Rehabilitation Act would fail because Section 503 provides no private right of action, and dismissed the action with prejudice.

Holdings

1. Golden's breach-of-contract claims were fully preempted by § 301 of the Labor Management Relations Act because resolving whether Verizon breached the collective bargaining agreements required interpretation of those agreements.
2. Res judicata barred Golden's claims because the prior action was adjudicated on the merits, involved the same parties, and arose from the same nucleus of operative fact as the present action.
3. Golden could not maintain an independent claim under § 503 of the Rehabilitation Act because § 503 does not provide a private right of action.

Questions Presented

1. Whether Golden's breach-of-contract claims based on alleged violations of collective bargaining agreements were preempted by § 301 of the Labor Management Relations Act.
2. Whether res judicata barred the claims because they arose from the same nucleus of operative fact as Golden's prior federal action, which had been dismissed as time-barred.
3. Whether Golden could maintain an independent private claim under § 503 of the Rehabilitation Act.
4. Whether the complaint should be dismissed with prejudice under Rule 12(b)(6).

Disposition

dismissed