Background
Daniel Delacruz appealed pro se from a district court judgment dismissing his action alleging various federal and state law claims against his former nurse and former employers.
The court’s reasoning
The panel reviewed the dismissal de novo under Federal Rule of Civil Procedure twelve comma six. The court affirmed because Delacruz failed to allege facts showing that defendant Claudia Quirarte was a recipient of federal financial assistance required for Rehabilitation Act liability. The court also affirmed the dismissal of the Section one thousand nine hundred eighty-one claim because Delacruz failed to allege race-based discrimination. Additionally, the district court did not abuse its discretion in declining supplemental jurisdiction over state law claims or in denying leave to amend because amendment would have been futile.
What it means going forward
The decision reinforces the narrow scope of liability under the Rehabilitation Act and Section one thousand nine hundred eighty-one, requiring specific factual allegations regarding federal funding recipients and race-based discrimination.
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