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Zohran Mamdani - Complaint","","Federal court complaint filed in the Southern District of New York by Yi Fang Chen on behalf of her minor children against Zohran Mamdani, the New York City Department of Education, and related officials. The pleading challenges New York City’s Specialized High School admissions policies, alleging the Discovery program reserves 20% of seats using criteria designed to alter racial composition and thereby disadvantage Chinese American students. 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The defendants are Zohran Mamdani (as Mayor), Kamar H. Samuels (as Chancellor), and the New York City Department of Education.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What admissions policy does the complaint challenge?",{"text":117,"@type":113},"The complaint challenges New York City’s Specialized High School admissions Discovery program, which reserves 20% of seats through a separate admissions pathway.",{"name":119,"@type":110,"acceptedAnswer":120},"What legal rights does the complaint claim were violated and what relief is requested?",{"text":121,"@type":113},"The complaint alleges violations of the Equal Protection Clause and Title VI for race-based disadvantage in admissions, citing Students for Fair Admissions. 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SAMUELS, in his official capacity as Chancellor of the New York City Department of Education; and the  \nNEW YORK CITY DEPARTMENT OF EDUCATION,  \nDefendants.  \nCase No. 1:26-cv-03355  \nCOMPLAINT  \nINTRODUCTION  \n[1. M.P. is](1. M.P. is) the son of Chinese immigrants. He is also a high-achieving New York City public school student who seeks admission to Stuyvesant High School, one of the most selective public schools in the nation. He recently took the Specialized High School Admissions Test (SHSAT) and ranked Stuyvesant as his first choice. He missed admission by three points. But for the City’s racially motivated set-aside of 20 percent of Stuyvesant’s seats for students who scored more than 60 points below M.P., he would have been admitted.  \n2. New York City’s specialized high schools (SHSs) are among the most academically rigorous public high schools in the nation. Starting in 2020, the City began reserving 20 percent of its SHS seats for a separate admissions pathway—the Discovery program—that excludes students based on criteria the City purposefully selected to change the racial composition of those schools. The City adopted and continues to enforce that policy in an  \nCase 1:26-cv-03355 Document 1 Filed 04/23/26 Page 2 of 22  \neffort to reduce the number of Asian-American students and increase the number of black and Hispanic students admitted to the SHSs.  \n3. Because of that racially discriminatory policy, M.P., a Chinese American, lost the opportunity to compete for all available seats and was not admitted to his preferred school. Unless the policy changes, his siblings Ma.P. and P.P. will face the same discrimination.  \n4. Plaintiff Yi Fang Chen—the mother of M.P., Ma.P., and P.P.—came to the United States to build a better life for herself and her children. She has lived and worked in New York City for decades and raised her family with the expectation that merit—not race—would determine their opportunities in public education.  \n5. Chen brings this action to vindicate her and her children’s rights under the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act of 1964, which forbid the government from structuring admissions policies to disadvantage students because of their race.  \n6. In Students for Fair Admissions, Inc. v. President & Fellows of Harvard College, 600 U.S. 181 (2023), the Supreme Court held that government officials may not manipulate admissions systems—whether through explicit classifications or facially neutral proxies—to produce race-based outcomes. Defendants have done exactly that here. Chen requests declaratory and injunctive relief to remedy that constitutional violation and to restore a race-neutral admissions process in which students like M.P. can compete on equal terms.  \nJURISDICTION AND VENUE  \n7. This action arises under the Fourteenth Amendment to the United States Constitution; 42 U.S.C. § 1983 ; and Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000det seq. The Court has jurisdiction over these federal claims under 28 U.S.C. §§ 1331 (federal  \nCase 1:26-cv-03355 Document 1 Filed 04/23/26 Page 3 of 22  \nquestion) and 1343(a) (redress for deprivation of civil rights) . Declaratory relief is authorized by the Declaratory Judgment Act, 28 U.S.C. §§ 2201–2202.  \n8. Venue is proper in this district under 28 U.S.C. § 1391(b)(1)–(2) . Defendants reside within this district and a substantial part of the events giving rise to the claim have occurred or will occur in the Southern District of New York.  \nPLAINTIFF  \n9. Plaintiff Yi Fang Chen was born in China; she moved to the United States in 1996 as a teenager. Although she came to this count","cbCaiu58edNHeEGi","https://ap.wps.com/l/cbCaiu58edNHeEGi","pdf",386762,22,"English","# Introduction\n# Jurisdiction and Venue\n# Plaintiff","[{\"question\":\"Who is the plaintiff and who are the defendants?\",\"answer\":\"The plaintiff is Yi Fang Chen, individually and on behalf of her minor children. The defendants are Zohran Mamdani (as Mayor), Kamar H. Samuels (as Chancellor), and the New York City Department of Education.\"},{\"question\":\"What admissions policy does the complaint challenge?\",\"answer\":\"The complaint challenges New York City’s Specialized High School admissions Discovery program, which reserves 20% of seats through a separate admissions pathway.\"},{\"question\":\"What legal rights does the complaint claim were violated and what relief is requested?\",\"answer\":\"The complaint alleges violations of the Equal Protection Clause and Title VI for race-based disadvantage in admissions, citing Students for Fair Admissions. It seeks declaratory and injunctive relief to restore a race-neutral admissions process.\"}]","Yi Fang Chen v. Zohran Mamdani - Complaint | PDF",55]