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Riboldi v. Warren County Department of Human Services Div. of Temporary Assistance & Social Services

United States District Court, D. New Jersey

April 25, 2018

MATTHEW RIBOLDI, Plaintiff,
v.
WARREN COUNTY DEPARTMENT OF HUMAN SERVICES DIV. OF TEMPORARY ASSISTANCE AND SOCIAL SERVICES, and WORK FIRST NEW JERSEY, Defendants.

          MEMORANDUM AND ORDER

          PETER G. SHERIDAN, U.S.D.J.

         This matter comes before the Court on the motions of Defendant Warren County Department of Human Services Division of Temporary Assistance and Social Services (Warren County), and Defendant Work First New Jersey's (State) to dismiss Plaintiff Matthew Riboldi's Second Amended Complaint (ECF 50 and 51) for failure to state a claim. For the reasons discussed herein, Defendants' motions to dismiss are granted.

         I.

         In this action, Plaintiff alleges that Defendants violated the Americans with Disabilities Act (ADA) by delaying his Supplemental Nutrition Assistance Program ("SNAP") benefits and medical benefits by failing to provide job training, and by failing to accommodate his disability at his hearing to determine benefits eligibility. He also alleges that the failure to accommodate his disabilities violated his due process rights.

         Plaintiff Matthew Riboldi originally applied for disability benefits on August 1, 2013 in Warren County because he had become homeless. [SAC at 1; ECF 45]. He applied for food stamps benefits under SNAP, emergency assistance benefits, general assistance benefits, and medical assistance benefits. [Id. at 1]. Warren County granted SNAP benefits and medical assistance, but denied the other assistance programs. Plaintiff alleges that Defendants violated the Americans with Disabilities Act by delaying his SNAP benefits for 50 days and medical assistance benefits for approximately 120 days because he submitted all necessary paperwork to Warren County to support his request for disability accommodations. [Id.]

         Plaintiff was found ineligible for both general assistance and emergency assistance benefits. Warren County denied Plaintiff general assistance benefits because he had a prior drug distribution conviction in violation of program requirements. See N.J.A.C. 10:90-2.8(a)(8) and N.J.A.C. 10:90-18.6. [ECF 37 at 4, Letter from the Department of Human Services, Final Decision affirming previous decision by the Agency to deny Petitioner WFNJ/GA)].[1] Plaintiff appealed and, in January 2014, the denial of benefits was affirmed by Administrative Law Judge Gail M. Cookson.[2] [SAC at 3].

         In contrast, Warren County initially granted Plaintiff SNAP benefits and Plaintiff received these benefits from December 2013 to June 2015. [SAC at 1, 4]. Warren County did not exempt Plaintiff from the work/training requirement for SNAP eligibility because a physician, who examined Plaintiff, found that he was not mentally or physically disabled and was able to work. [Def. Warren County's Reply at 3, ECF 56]. Warren County revoked Plaintiffs SNAP eligibility in June 2015 and closed his case because Plaintiff failed to meet this work/training requirement since Plaintiff failed to attend mandatory career counseling meetings with Warren County employees. [SAC at 6-7].

         Plaintiff further alleges that Defendants made no attempt to make reasonable disability accommodations for him, even though Defendants knew about his disability accommodation needs. [SAC at 3].

         Based on Defendants' denial of benefits and failure to address his fair hearing and accommodation request, Plaintiff brings this present cause of action, alleging:

(1) Violation of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq.; and
(2) Violations of the Fifth and Eleventh Amendments of the U.S. Constitution.

[SAC at 2-3]. Defendants seek dismissal of these claims pursuant to Fed.R.Civ.P. 12(b)(6) because Plaintiff fails to plead sufficient facts to maintain claims for violations of the ADA or due process rights. [ECF 50, 51].

         III.

          First, the Court notes that Plaintiff is proceeding pro se, and for that reason "we construe his complaint in the way most favorable to him." Carr v. Sharp, 454 F.2d 271, 272 (3d Cir. 1971).

         On a motion to dismiss for failure to state a claim pursuant to Fed.R.Civ.P. 12(b)(6), the Court is required to accept as true all allegations in the Complaint and all reasonable inferences that can be drawn therefrom, and to view them in the light most favorable to the non-moving party. See Oshiver v. Levin,38 F.3d 1380, 1384 (3d Cir. 1994). "To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face."' Ashcroft v. Iqbal,556 U.S. 662, 678 (2009) (quoting Bell Atl Corp v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)). While a court will accept well-pleaded allegations as true for the purposes of the motion, it will not accept bald assertions, unsupported conclusions, unwarranted inferences, or sweeping legal conclusions cast in the form of factual allegations. Iqbal, 556 U.S. at 678-79; see also Morse v. ...


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