This Complaint does not seek civil damages or attorney's fees. Instead, it asks the City of New York to order Midnite and its leadership to restrain discriminatory and retaliatory practices. It does not request monetary damages.

The Complaint alleges that the individual respondents (Joel Brooks and Michael Padula) ignored requests from the Complainant and the woman he saved from an attack to stop engaging in unlawful discriminatory conduct. It further alleges others were muted during business meetings or silenced with bans when they raised complaints about his treatment. Furthermore, it claims that when made aware of the administrative complaint, Respondents Joel Brooks and Michael Padula abruptly announced intentions to resign. However, the Complainant asserts that they continue to make decisions impacting the group and facility. The Complaint makes it clear - they may face liability beyond the scope of their long-time positions as Midnite's key decision-makers in subsequent litigation.

AA's 2nd Tradition, cited below, generally opposes hierarchical governance within AA groups. However, the Complaint alleges that Midnite's leadership used formal titles, like "Corporation President," to exercise discriminatory authority and block fair decision-making within the group.

"When told that our Society has no president having authority to govern it, no treasurer who can compel the payment of any dues, no board of directors who can cast an erring member into outer darkness, when indeed no A.A. can give another a directive and enforce obedience, our friends gasp and exclaim, 'This simply can’t be. There must be an angle somewhere.'"

– Twelve Traditions - Tradition Two - (pp. 132-138)

The Complaint alleges that Midnite's leadership blocked the group’s right to vote on the decision to exclude the Complainant and other key matters. It alleges this decision-making was controlled solely by the Corporation President and the Group Overall. The Complaint further alleges that certain decision-making processes were not followed.

A redacted version of the Complaint is available on the homepage for public review.

Yes, your privacy is a priority. Information provided to the NYC Commission on Human Rights is protected under applicable confidentiality laws. For information about filing a complaint or providing information, contact the Commission directly.

The investigation is ongoing, and information about discriminatory practices is of interest to the Commission. We encourage anyone with information about this case to come forward and to do it quickly. You may contact the investigation team confidentially (a form will be available soon) or the City of New York by dialing 311 and asking for "Human Rights."