D'Anzieri v. HHarrison Global LLC

Background

Lenore D’Anzieri sued Harrison Global LLC, a privately owned chauffeured transportation company, and Steven Pitel, identified as her former supervisor. She alleged discrimination, failure to accommodate, and retaliation under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the New York City Human Rights Law, and the New York State Human Rights Law. The opinion states that the court had previously dismissed D’Anzieri’s disability-discrimination and failure-to-accommodate claims against Harrison Global and dismissed all but her sex-discrimination claims against Pitel for lack of personal jurisdiction.

D’Anzieri worked for Harrison Global from approximately July 2016 until her employment ended on or about March 20, 2020. She alleged that Pitel and the company discriminated against her based on sex and age, retaliated against her after she complained and filed a charge with the Equal Employment Opportunity Commission, and terminated her while retaining younger male employees. The defendants disputed much of the factual basis for those allegations.

Defendants’ Motion

The defendants moved for summary judgment. They renewed their argument that the court lacked personal jurisdiction over D’Anzieri’s remaining claims and also argued that the undisputed facts entitled them to judgment on the merits. Personal jurisdiction is a court’s authority to decide claims against a particular defendant based on the defendant’s connections to the forum state.

The opinion focused on New York’s long-arm statute, which can permit jurisdiction over an out-of-state defendant that transacts business in New York, commits a tortious act in New York, or commits a tortious act elsewhere that causes injury in New York under specified conditions. The court explained that specific jurisdiction is claim-specific, meaning that the connection must be examined separately for each claim.

Personal Jurisdiction Over Harrison Global

The court held that it lacked personal jurisdiction over Harrison Global concerning D’Anzieri’s sex-discrimination claims. Harrison Global did not dispute that it conducted extensive business in New York, but it disputed that D’Anzieri’s claims arose from that business. The court had previously found jurisdiction adequately alleged at the motion-to-dismiss stage, but it explained that the summary-judgment record required admissible evidence supporting jurisdiction.

The defendants submitted onboarding documents, background-search results, tax forms, emails, and sworn declarations indicating that they understood D’Anzieri to be working remotely from Florida, Georgia, and New Jersey. D’Anzieri relied on assertions that company personnel knew she had lived in New York, that she told Pitel she had a New York apartment, and that her onboarding paperwork included a New York driver’s license and a prior New York address. The court found that this evidence did not create a genuine factual dispute about whether the defendants knew she resided or worked remotely in New York during the relevant period. The court also noted that D’Anzieri admitted she did not identify her location when joining calls from New York.

The court found that the alleged comment concerning drivers transporting Victoria’s Secret models had an arguable connection to Harrison Global’s New York business because the transportation service was provided for a New York fashion show. But it held that the remark, standing alone, was not sufficiently severe or directed at D’Anzieri to support her hostile-work-environment claim. The court found that the other provisions of New York’s long-arm statute did not provide jurisdiction either.

The court separately held that it lacked personal jurisdiction over Harrison Global’s age-discrimination claims because D’Anzieri had not supported her assertion that AmexGBT was based in New York with admissible evidence. It also held that it lacked personal jurisdiction over her retaliation claims because she had not shown that the defendants knew she worked remotely from New York and therefore could not establish that they could reasonably have expected her termination to cause injury there.

Personal Jurisdiction Over Pitel

The court held that it also lacked specific personal jurisdiction over Pitel concerning D’Anzieri’s sex-discrimination claims. The court relied on its conclusion that D’Anzieri had not presented evidence creating a triable factual question about whether Pitel knew she worked remotely from New York. The alleged comment connected to the New York fashion show was insufficient by itself to support jurisdiction over the claim.

Transfer Rather Than Dismissal

The court explained that a dismissal for lack of jurisdiction would not decide the merits of D’Anzieri’s discrimination claims. It stated that the usual course would be to deny the defendants’ summary-judgment motion without prejudice and dismiss the lawsuit without prejudice. But federal law also permits a court to transfer a case to a court that could exercise personal jurisdiction when transfer would serve the interests of justice.

The parties’ briefing had not addressed important transfer-related facts, including which courts could exercise personal jurisdiction and whether a dismissal could create statute-of-limitations problems. Because of the lawsuit’s lengthy history and the parties’ apparent agreement that Harrison Global was domiciled in Massachusetts, the court indicated that it was inclined to transfer the case to the District of Massachusetts.

Disposition

The court concluded that it lacked personal jurisdiction over the action. It directed the parties to meet and confer about whether the case should be transferred and, if so, to which district. The parties were ordered to submit a joint letter by July 17, 2025, explaining why the case should not be transferred to the District of Massachusetts and stating their positions if they could not agree. The opinion did not decide the merits of D’Anzieri’s discrimination or retaliation claims and did not itself order a transfer.