Williams v. Westchester Medical Center Health Network

Background

Garfield Williams, proceeding without a lawyer, sued Westchester Medical Center Health Network, identified in the opinion’s allegations as Westchester County Health Care Corporation, along with Marcela Steger, Jason Yoakum, and Kenneth Osario. He asserted claims under 42 U.S.C. § 1981, Title VII of the Civil Rights Act, the Family and Medical Leave Act, the New York State Human Rights Law, and several New York Labor Law provisions.

Williams alleged that Steger threatened and insulted him after an operating-room incident, including allegedly making racist and sexist comments. He said he complained to supervisors and Human Resources, was later moved from the Ambulatory Care Center to the main operating room, and viewed that move as a demotion because it reduced his professional-development opportunities. After a December 2019 car accident, Williams alleged that he continued to experience neck, back, and arm pain, used sick time, informed supervisors of his condition, and began applying for Family and Medical Leave Act leave. He alleged that Yoakum and Osario accused him of unexcused absences and that his employment was terminated effective February 12, 2020. He also alleged that defendants later posted a “Wanted Poster” and refused to verify his employment for a no-fault insurance claim.

Motion to dismiss

Defendants moved to dismiss the third amended complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint plausibly states a legal claim. The court treated well-pleaded allegations as true for this motion and interpreted the self-represented plaintiff’s allegations liberally, but explained that this standard does not excuse compliance with substantive and procedural law.

Discrimination claims

The court dismissed Williams’s race- and sex-discrimination claims under Section 1981, Title VII, and the New York State Human Rights Law. It concluded that the alleged comments, the “Wanted Poster,” the alleged failure to take Williams’s medical complaints seriously, the different treatment of Steger, and the transfer allegations still did not plausibly connect an adverse employment action to racial or sex-based discrimination. The court also concluded that Steger was not an adequate comparator because Williams did not allege that she had a similar record of unscheduled absences, which the termination letter identified as one reason for his firing. These discrimination claims were dismissed with prejudice.

Retaliation claims

The court ruled that Williams’s Title VII retaliation claims were untimely as to the alleged October 23, 2019 transfer. Although the court accepted Williams’s allegation that he attempted to file an Equal Employment Opportunity Commission charge on November 25, 2020, it concluded that this was more than 300 days after the transfer. The court dismissed the Title VII retaliation claim as untimely, with prejudice.

The court allowed some retaliation claims to proceed. It concluded that Williams plausibly alleged protected activity when he complained to Yoakum, other supervisors, and Human Resources about allegedly racist and sexist statements and threats. It also concluded that the alleged transfer could qualify as a materially adverse action because Williams alleged that it reduced his relationships with respected doctors and his opportunities for advancement. The court found that the two-week period between the complaints and the transfer plausibly supported a causal connection. It therefore denied the motion as to Williams’s race-based retaliation claim under Section 1981 and his race- and gender-based retaliation claims under the New York State Human Rights Law, but only as to the individual defendants. The court concluded that the later termination, “Wanted Poster,” and refusal to verify employment were too far removed from the protected activity to support causation at this stage.

Family and Medical Leave Act claim

The court denied the motion to dismiss Williams’s Family and Medical Leave Act interference claim, except as to Steger. The court concluded that Williams plausibly alleged a serious health condition because he alleged more than three days of incapacity and at least two medical visits within 30 days for the same underlying accident-related pain. It also concluded that he plausibly gave notice that the Family and Medical Leave Act might apply by informing supervisors about his continuing pain and absences and beginning a leave application; a completed formal application was not required at the pleading stage.

The court dismissed the Family and Medical Leave Act claim against Steger because Williams did not allege her personal involvement in the events surrounding his leave request. The court allowed the claim against Yoakum and Osario to proceed because Williams alleged that they classified his absences as unexcused despite knowing about his condition and leave application, which was sufficient at this stage to suggest they exercised some control over his leave-related employment conditions.

Other claims and disposition

Williams withdrew his New York Sick Leave Law claim, New York Labor Law § 741 claim, and breach-of-contract claim, and the court dismissed those claims. The court also disregarded the duplicative Title VII sex-discrimination count. Overall, the court granted in part and denied in part defendants’ motion to dismiss. Judge Kenneth M. Karas directed the Clerk of Court to terminate the motion and scheduled a telephone conference for May 8, 2025.