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Naiman v. New York University

1997 WL 249970 (1997)

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Naiman v. New York University

United States District Court for the Southern District of New York
1997 WL 249970 (1997)

  • Written by Arlyn Katen, JD

Facts

Alec Naiman (plaintiff), a deaf man, was an emergency-room patient at New York University Medical Center (NYUMC) twice in 1993 and twice in 1995. During each visit, Naiman requested a sign-language interpreter. On Naiman’s first and third visits, NYUMC failed to provide a sign-language interpreter. On Naiman’s second visit, after Naiman had been at NYUMC for most of the day, NYUMC provided a person with minimal sign-language ability who was largely unable to understand Naiman. Finally, on Naiman’s fourth visit, NYUMC failed to present a sign-language interpreter in a timely manner. Naiman sued the operator of NYUMC, New York University (NYU) (defendant), in federal district court. Naiman asserted that NYUMC’s failure to provide a qualified sign-language interpreter denied Naiman the ability to meaningfully participate in his own medical care. Naiman sought injunctive and monetary relief under the Americans with Disabilities Act (ADA), the Rehabilitation Act (RA), and state law. NYU moved to dismiss Naiman’s complaint, arguing in relevant part that Naiman did not have legal standing to seek injunctive relief because Naiman had failed to prove that there was a real or immediate threat that Naiman would be wronged again. The district court considered NYU’s motion.

Rule of Law

Issue

Holding and Reasoning (McKenna, J.)

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