Rys v. Davis

Background

Samantha Rys sued Sabrina Davis and Tanya Johnson under 42 U.S.C. § 1983, alleging that they violated the Equal Protection Clause of the Fourteenth Amendment by subjecting her to a race-based hostile work environment and constructively discharging her. Rys worked as a parole officer for the New York State Department of Corrections and Supervision from approximately May 2021 until her resignation in August 2021. Johnson supervised Rys, and Davis was a Bureau Chief to whom Johnson reported.

Rys argued that the defendants treated her differently because she was Caucasian. She relied on allegations that she was not given a field partner, received a more burdensome workload than Black parole officers, and was assigned hospital duty involving parolee A.R. despite threats against her. Rys also relied on a coworker’s race-related “spray tan” comment and later described another race-related comment in her declaration. The defendants moved for summary judgment, asking the court to rule that no genuine dispute of material fact required a trial.

Court’s Analysis

The court concluded that Rys’s declaration was a “sham affidavit” because it contradicted or added materially to her deposition testimony. Among other things, she had testified that she did not know her coworkers’ caseloads but later declared that Black parole officers had fewer precincts; she had testified that her jurisdiction involved two precincts but later declared that she had three; and she described an additional race-related incident in her declaration that she had not mentioned during her deposition. The court therefore would not credit those new or contradictory assertions to create factual disputes.

For the hostile-work-environment claim, the court assumed for purposes of analysis that the defendants acted under color of state law because they were state employees acting as Rys’s supervisors. But the court held that Rys failed to show that the alleged hostility occurred because she was Caucasian. The court found that Johnson assigned training and office partners, but not field partners, and that other parole officers’ reluctance to accompany Rys in the field did not establish discriminatory conduct by Davis or Johnson.

The court also found no admissible evidence showing that Rys had more cases than her Black coworkers or otherwise received a disproportionately burdensome workload. The court treated the handling of A.R.’s threats as facially race-neutral and found that Rys offered no circumstantial evidence connecting that conduct to race. Although a coworker made the “spray tan” comment, Rys did not report it to either defendant, and she did not show that the defendants were personally involved in, or responsible for, the coworker’s comments. The court further stated that being the only Caucasian employee in the office, standing alone, did not support an inference of discrimination.

For constructive discharge, the court explained that the claim requires working conditions so intolerable that a reasonable person would feel compelled to resign, a standard higher than the hostile-work-environment standard. Because Rys failed to establish the underlying hostile-work-environment claim, the court held that the constructive-discharge claim also failed.

Disposition

The court granted Defendants’ Motion for Summary Judgment in its entirety. It directed the Clerk of Court to enter judgment, terminate the pending motion, and close the case.