Watkins v. The City Of New York

Background

Shauntay Watkins sued her former employer, the New York City Transit Authority (NYCTA), under 42 U.S.C. § 1981 and the New York City Human Rights Law (NYCHRL). She alleged that fellow probationary employee Tequisha Jenkins, a darker-skinned African American woman, repeatedly directed race-based insults at Watkins, a lighter-skinned African American woman, during train-operator training.

The court previously dismissed Watkins’s retaliation and other related claims on summary judgment. It allowed her federal and City hostile-work-environment claims to proceed to trial. After a four-day trial, the jury found that Watkins had not proved a hostile work environment and returned a verdict for NYCTA.

Motion for a New Trial

Watkins moved for a new trial under Federal Rule of Civil Procedure 59. She argued that the court improperly excluded evidence about a February 21, 2016 argument with Jenkins, the resulting investigation, and Watkins’s termination. Watkins said those events should have been considered as part of the full circumstances of the alleged hostile work environment.

The February 21 argument occurred when Watkins turned on a train’s headlights while Jenkins was still on the tracks. Watkins said Jenkins cursed at her, threatened her, and continued the earlier harassment. Other testimony described an argument involving both women. NYCTA terminated both Watkins and Jenkins for violating a workplace rule against altercations.

Before and during trial, the court limited the evidence about the incident and termination. Watkins could tell the jury that she had been involved in an altercation, attended meetings, provided information, and received a termination letter. The court instructed the jury not to consider the February 21 incident, the investigation, or the termination when deciding Watkins’s hostile-work-environment claims or damages. Neither party objected after the court delivered the charge.

Court’s Analysis

A new trial may be ordered when a jury reaches a seriously erroneous result or when its verdict is against the weight of the evidence. The court emphasized that it should give substantial deference to the jury’s assessment of witness credibility and should not replace the jury’s judgment merely because it might view the testimony differently.

For the federal claim under Section 1981, the court explained that Watkins had to show repeated race-based conduct that was severe or pervasive enough to create an abusive working environment. The court found that the excluded evidence was not relevant to that claim. The February 21 incident was not explicitly racial, occurred after Watkins and Jenkins had been separated for two months, and appeared connected to the immediate train-lighting incident rather than the earlier alleged harassment. Allowing the evidence also could have confused the jury by reviving the retaliation issue that had already been dismissed.

The court further concluded that the evidence presented at trial gave the jury several permissible reasons to reject Watkins’s account. Watkins was the only one of seven possible witnesses who testified that Jenkins made the alleged racial remarks in class. Other witnesses denied hearing those remarks. The jury could also have found that the alleged comments were not sufficiently continuous, were motivated by disputes about Watkins’s military-service claims rather than race, or did not create an abusive environment. Because the verdict depended heavily on credibility determinations, the court would not second-guess it.

The court applied the lower standard governing the NYCHRL claim, under which a plaintiff must show that she was treated less well because of discriminatory intent. It nevertheless reached the same conclusion. The February 21 incident and termination were not relevant to the surviving hostile-work-environment claim. The jury could have believed that Jenkins’s conduct concerned Watkins’s military-service representations rather than her race, and it could have considered that both women were terminated for violating the same workplace rule. The court also noted that the jury could have found the alleged conduct to be petty slights or trivial inconveniences under the NYCHRL defense, although the jury did not reach that issue.

Jury Instruction

The court held that the jury instructions correctly stated the legal standards for the Section 1981 and NYCHRL claims. Even if the instruction excluding the February 21 incident and related evidence had been mistaken, the court concluded that any mistake would have been harmless because the evidence was unlikely to have changed the verdict.

Disposition

Judge Edgardo Ramos denied Watkins’s motion for a new trial. The court directed the Clerk of Court to terminate the motion.