Buckler v. Craft Beekman, LLC

Background

The plaintiff alleged that he had worked as a maître d’ for Craft Beekman, LLC, also identified as Temple Court, at the Temple Court bar and restaurant. He alleged that he was terminated on March 22, 2023, after being told that coworkers and patrons had complained that he was racist. The complaint alleged that the plaintiff was white, that he had complimented a Black patron’s appearance before his termination, and that he was later replaced by a Hispanic woman.

The plaintiff sued Craft Beekman, Temple Court, Tom Colicchio, and Darren Dunn. He asserted race-discrimination claims under 42 U.S.C. § 1981 and the New York City Human Rights Law. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim.

Section 1981 claim

The court dismissed the federal race-discrimination claim. It explained that the complaint needed to provide at least minimal factual support for the conclusion that the defendants acted with discriminatory intent. The court found no allegation that the defendants mentioned the plaintiff’s race or treated him differently from similarly situated non-white employees.

The court rejected the plaintiff’s theory that he would not have been accused of racism if he were not white. Relying on Second Circuit precedent, the court stated that “racism” is not a race and that accusing someone of racism does not, without more, show that the person was rejected because of his race. The court also considered the allegation that the plaintiff was replaced by a Hispanic woman but concluded that, viewed together with the complaint’s allegations about complaints from patrons and coworkers and the human-resources investigation, the facts did not support even a minimal inference of racial motivation.

New York City Human Rights Law claim

The court separately analyzed the New York City Human Rights Law claim because that law provides broader protection than corresponding federal and state standards. Even under that more liberal standard, the court found that the plaintiff had not plausibly alleged that he was fired because of his race or provided facts connecting his termination to a discriminatory motive. The court therefore dismissed that claim as well.

Disposition

The court granted the defendants’ motion to dismiss. It dismissed the action with prejudice and directed the Clerk of Court to close the case. The opinion explained that the plaintiff had previously received leave to amend and that the earlier order had described that opportunity as his last chance to amend in response to the defendants’ identified issues.

Judge

The opinion was issued by United States District Judge Margaret M. Garnett.