Linfante-Hill v. PVH Corp.

Background

Christine Linfante-Hill sued PVH Corp., her former employer, under the New York City Human Rights Law (NYCHRL), alleging age discrimination. She alleged that PVH terminated her because of her age and replaced her with Ilir Morina, a younger and less qualified employee. PVH removed the action from New York state court to the U.S. District Court for the Southern District of New York.

Linfante-Hill began working for PVH in October 2017, when she was 49 years old. She held several positions and received generally positive performance reviews. In 2021, her manager, Lisa Kilgallon, began looking for someone to improve PVH’s business-process-management practice. Linfante-Hill said she expressed interest but was told she did not need to interview. PVH hired Morina for the position in September 2022. Morina was 47, seven years younger than Linfante-Hill at that time.

Around August 2022, PVH began a reduction in force to implement a new global operating model, reduce costs, and increase efficiency. PVH said Linfante-Hill was terminated because her position had become obsolete under that model. On September 28, 2022, Kilgallon notified Linfante-Hill of her termination and directed her to transfer her work to Morina. PVH disputed that Morina replaced Linfante-Hill but conceded that Morina assumed at least some of her responsibilities.

Motion and Legal Standard

PVH moved for summary judgment. Summary judgment is an early ruling that is appropriate when the evidence shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. The court views disputed facts and reasonable inferences in favor of the party opposing the motion.

The NYCHRL prohibits an employer from discriminating against an employee because of the employee’s actual or perceived age. The court explained that the NYCHRL uses a broad standard: an employee need only show that the employer treated her less well, at least partly for a discriminatory reason. The court applied the burden-shifting framework commonly used in employment-discrimination cases.

Court’s Analysis

The parties disputed only whether Linfante-Hill’s termination occurred under circumstances suggesting age discrimination. The court held that she presented enough evidence for a reasonable jury to draw that inference. The evidence included that she transferred all of her work to Morina, that Morina assumed at least some of her responsibilities, and that another younger employee took over some responsibilities of another employee affected by the reduction in force.

The court rejected PVH’s argument that Morina’s age defeated the claim because Morina was also within the age-protected category. A plaintiff does not have to show that her replacement was outside the protected category to establish an initial case of age discrimination.

The court also held that PVH had provided a legitimate, nondiscriminatory reason for the termination: the reduction in force and its stated economic and organizational objectives. But the court found a genuine factual dispute about whether that explanation was a pretext, meaning an explanation that concealed an impermissible reason. Linfante-Hill had evidence of positive performance reviews, qualifications and experience relevant to Morina’s role, the transfer of her responsibilities to Morina, and PVH’s failure to consider her for that role.

Disposition

The court denied PVH’s motion for summary judgment. It concluded that a reasonable jury could find that PVH’s stated reason for terminating Linfante-Hill was a pretext for intentional age discrimination. The order did not decide whether PVH actually discriminated against Linfante-Hill. The parties were directed to advise the court by September 29, 2025, whether they wanted a settlement conference or intended to proceed to trial.