Testimony of Tahmir Williams and Maureen Belluscio, NYLPI Disability Justice Program, to the NYC Council Committee on Civil and Human Rights Regarding FY2025

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Testimony of  Tahmir Williams, Legal Intern, Disability Justice Program and Maureen Belluscio, Managing Attorney, Disability Justice Program, New York Lawyers for the Public Interest, to the New York City Council  Committee on Civil and Human Rights regarding Oversight – Preliminary Budget Hearing, New York City Commission on Human Rights March 15, 2024 

Our names are Tahmir Williams and Maureen Belluscio. We work in the Disability Justice  Program at New York Lawyers for the Public Interest (“NYLPI”). NYLPI is a civil rights  organization with a robust disability rights practice. NYLPI is also a member of the New York  City Human Rights Law Working Group, and we submit this testimony to support the  testimonies of our colleagues in this coalition and to amplify the testimony of the community  members here today to support increasing the New York City Commission on Human Rights’  budget.  

NYLPI’s Disability Justice Program represents people in disability rights and anti-discrimination  matters, including before the New York City Commission on Human Rights (“Commission”). A  fully functioning Commission, which enforces and maintains the strength of the New York City  

Human Rights Law (“NYCHRL”), is critical to the lives of countless New Yorkers. The  NYCHRL provides important protections against disability discrimination, protections that go  far beyond those available under analogous state and federal anti-discrimination laws.  

We appreciate the opportunity to provide testimony to urge that New York City fully fund the  New York City Commission on Human Rights, and thereby protect our communities from  discrimination.  

A Fully Functioning Commission is Critical for All New Yorkers 

The Commission is charged with enforcing the NYCHRL, which protects the most vulnerable  New Yorkers from discrimination. The NYCHRL is the strongest anti-discrimination law in the  

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United States, reflecting our city’s culture of equality and equity. Among other categories, this law protects New Yorkers from discrimination based on their race, gender, disability, gender  orientation, immigration status, religion, national origin, hair, source of income, criminal  background, and pregnancy. In nearly every year in the past decade, the City Council has added  more protections to the Law in some way. Since 2013, the City Council has passed more than 40  separate far-reaching amendments to the law. 

Unfortunately, the work the Commission does to enforce these critical civil rights protections has  been undermined by underfunding, which has resulted in severe understaffing. Through years of  budget cuts, vacancy reductions, and resignations by overstretched workers, staffing levels at the  

Commission have sharply declined. In 2018, the Commission had almost 50 attorneys working  in the Law Enforcement Bureau enforcing the NYCHRL, in addition to 13 supervising attorneys.  Today, the Law Enforcement Bureau has shrunk by an alarming percentage, with only 23 attorneys in total to enforce the law for over 8 million New Yorkers. In fact, in FY23, the  Commission fielded a record 12,190 inquiries from members of the public alleging  discrimination, yet only resolved 471 filed cases. The Commission is already operating well  below capacity and cannot withstand any further cuts. On the contrary, staffing levels at the  Commission must be adequately raised to meet the incredible demand for its services. 

The Commission Provides Unique Services Not Available Anywhere Else 

One of the most critical aspects of the Commission’s work is prosecuting violations of the  NYCHRL on behalf of pro se litigants. Often, the Commission provides the only opportunity for  pro se litigants to enforce their civil rights. This is an indispensable and otherwise unavailable  service to the people of New York City. Pro se litigants, in particular, are negatively affected by the results of the Commission’s underfunding and understaffing: lengthy wait times for intakes,  cases taking years to be adjudicated, bad actors going unpunished, administrative hearings  lingering with no resolution, and cases being administratively closed that could and should have  been resolved. The process of filing and resolving complaints at the Commission has slowed to a  standstill. In short, pro se New Yorkers are denied access to one of the only venues available to  enforce their civil rights. The Commission does not currently have adequate resources to enforce  the NYCHRL to the detriment of all New Yorkers, and particularly those who have low income and are therefore pro se

The Commission also has the authority to conduct Commission-led investigations. This means  that the Commission can investigate systemic issues without having a named Complainant, based  merely on a report of discrimination. Commission-led investigations are particularly helpful in  circumstances where a potential Complainant may have a reason not to file a Complaint themselves. This is an incredibly important service to the communities NYLPI serves. For  example, when a hospital or other medical setting does not provide accessible services for  patients with disabilities, a patient may not want to file a Complaint because they would then feel  uncomfortable returning to that location to receive further medical care. NYLPI assisted a patient  to present a set of issues at a particular hospital to the Commission. Without requiring the patient  to hold themselves out as a Complainant, the Commission took this information and investigated 

a broader range of issues at all hospitals throughout the hospital system. Without the  Commission’s services, these critical access issues may have never been addressed. 

The Commission Requires a Significant Budget and Staffing Increase to Adequately Protect New Yorkers 

New York City—which has long touted itself a bastion of civil rights—has a Commission that  has continued to receive significantly less funding in its budget per capita than smaller cities like San Francisco, Washington D.C., and Seattle

At $14.1 million dollars, which Mayor Adams proposed reducing even further to $13.6 million  dollars in his FY2025 Preliminary Budget, the Commission’s budget is infinitely small compared  to the immense mission with which it has been tasked. Even doubled, the Commission’s entire  budget would remain less than 0.01% of the City’s total budget. 

To meet the incredible demand for the Commission’s services, our coalition’s budget ask for  FY2025 is as follows: 

  • Secure $3 million in new funding for the Commission’s Law Enforcement Bureau (LEB): 

o This funding would increase capacity at the LEB to mirror staffing levels in 2018,  which requires adding at least 34 attorneys, one assistant commissioner, as well as  supporting staff. 

  • Lift hiring restrictions and create new positions that allow the Commission a one-to one replacement for any staff turnover: 

o Currently, the Commission can only hire one staff member for every two vacancies, which hinders its ability to quickly staff up to meet case urgency. Implement competitive salary rates: 

o To attract and retain talent, the Commission must be allowed to raise salaries to  compete with nonprofit legal service providers in the city. 

Thank you for recognizing that, without a functioning Commission, justice simply cannot be  served in New York City.  

About the New York City Human Rights Law Working Group 

We are a coalition of advocates who work on issues related to discrimination. We assist New  Yorkers–most of them low-income–who seek to enforce their civil and human rights in the areas  of housing, employment, credit, public accommodations, and more. We are lawyers, paralegals,  organizers, and other advocates. We work at non-profits, at public interest law firms, and in the  private sector. What unifies us is our belief that a well-funded New York City Commission on  Human Rights is essential to the flourishing of New York City and to the safety, well-being, and  success of all New Yorkers.

About New York Lawyers for the Public Interest  

For nearly 50 years, NYLPI has been a leader in advocating for New Yorkers, working to  accomplish equality of opportunity for all. We utilize a community lawyering model to bridge  gaps between traditional civil legal services and civil rights advocacy and to fortify capacity for  both individual solutions and long-term impact.  

Our work encompasses comprehensive organizing, policy campaigns, impact litigation, and  individual legal services, and we are guided by the priorities of our communities as we advocate  for the rights of people with disabilities, equal access to health care, immigrant opportunity,  invigorated local non-profits, and environmental justice for low-income communities and  communities of color.  

NYLPI’s Disability Justice Program has represented thousands of individuals and triumphed in  numerous campaigns improving the lives of New Yorkers with disabilities. We have long fought  disability-based discrimination in housing, education, public accommodations, and government  services, and our landmark victories include access to New York City Housing Authority housing  for persons with disabilities, halting discrimination by charter schools against students with  disabilities, and access to the observation deck of the Empire State Building. 

Ongoing Support from NYLPI  

We thank the City Council for convening this important hearing. We appreciate the opportunity  to provide this written testimony on behalf of our clients and communities who deserve access to  the Commission’s much needed services. Please feel free to contact us at (212) 244-4664, ex.  9312 or [email protected]


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