The Appellate Division affirmed the Order which granted defendant's motion to dismiss the complaint and denied plaintiff's cross motion to amend the complaint to add the City of New York. Defendant, the New York City Human Resources Administration (HRA), is a City agency and, thus, is not a proper party to this action, pursuant to NY City Charter § 396. Plaintiff's motion to substitute the City for HRA was properly denied, as it was already decided against him in a prior order in this action. In any event, the complaint fails to state a claim against HRA, as the allegations do not implicate the agency.
Komatsu v. New York City Human Resources Admin., NY Slip Op 03410 (1st Dep't June 1, 2021)
