Civil Rights Allegations Against Midnite Group, Inc. and its Leadership

Civil Rights Allegations Involving Midnite Group, Inc., Joel Brooks, and Michael Padula

What parties are Respondents in the Complaint?
A formal civil rights complaint has been filed with the New York City Commission on Human Rights against Midnite Group, Inc. and two of its officials: Joel Brooks (identified in filings as Corporation President) and Michael Padula (identified in filings as Group Overall).

What is it alleged the Midnite AA Group did?

The complaint alleges multiple violations of NYC Human Rights Law including alleged misuse of emergency services, public defamation, and systematic suppression of the complainant's participation rights.

You've read the summary. Now view the Complaint.



Alleged Pattern of Misconduct

According to the administrative complaint, the following serious allegations are presented:

The complaint asserts these actions represent violations of multiple provisions of the NYC Human Rights Law.

What happened?

One August night earlier this year, the complainant—a young Black man—alleges he stepped in to protect an older White woman during a racially motivated assault outside the Midnite Group facility.

When he raised concerns about racial discrimination within the group, he claims that Midnite’s leadership, including Joel Brooks and Michael Padula, retaliated against him.

According to his complaint, the individuals banned him, accusing him of violence and weapon possession, allegations he denies. Witnesses, including the woman he protected, contradicted these claims and asked Midnite leadership stop using her attack for their vendetta. View her letter to Midnite leadership days after.

Despite this, the Complaint alleges that the Respondents above continued to post his name on a public “ban list,” attempted to portray him as violent, and blocked him from group events - even calling the police when he attempted to attend his milestone anniversary. As of the date of publication, Respondents have never apologized, permitted a vote on their decision, or corrected the record.

The Complaint alleges the refusal to address this situation demonstrates deliberate indifference - ultimately based on racist and exclusionary leadership choices that exposed the group to risk.

Legal Framework

The complaint alleges multiple violations of NYC Administrative Code:

  • Discriminatory Denial of Public Accommodation Access (§ 8-107(4)(2))
  • Unlawful Retaliation (§ 8-107(7))
  • Discriminatory Harassment (§ 8-107(19))

Remedies Sought

The complaint seeks immediate injunctive relief to address what it describes as ongoing civil rights violations, including:

How Are the NYPD Involved?

The Complaint alleges that after law enforcement repeatedly categorized the matter as a civil issue and declined further action, Respondents encouraged volunteers to continue calling 911, potentially exposing them to legal risk. Moreover, these actions allegedly violated § 8-107(19).


More Details

View the Letter to NYPD (redacted).

Evidence in the Complaint suggests that dispatchers did not initially respond to Midnite's calls. According to the Complaint, Respondents attempted to manipulate response times by making repeated claims of violence and weapon possession, despite allegedly knowing these claims were unsubstantiated.


The Complaint contends that Midnite leadership either knew or should have anticipated the claims would lack merit. However, these repeated interactions allegedly delayed the Complainant long enough to deny him access to meetings, in further violation of the law.

Important Legal Notices

All information presented is extracted directly from official public records The Commission has not yet made any findings regarding these allegations This website presents allegations as stated in official filings only The respondents deny (or have failed to respond) to all allegations. This information is provided for public interest purposes protected under law Updates will be posted as official proceedings progress.