Williams v. New York City Department of Education

Background

Wanda Williams worked as a per diem substitute teacher for New York City Public Schools beginning in 2012. In January 2014, she accepted a substitute assignment in a kindergarten class at Hernandez-Hughes School, P.S. 30M. She continued in that assignment through March 20, 2014.

The parties disputed how Williams’s assignment ended. Williams alleged that the school’s payroll secretary told her that she had to take one day off, and that Principal Teri Stinson and the payroll secretary then canceled her assignment. Williams also alleged that, under Department of Education and union rules, continuing in the assignment would have entitled her to the full-time position for the 2014–15 school year. Defendants argued that Williams stopped reporting to P.S. 30M and began accepting assignments at another school.

Williams sued in 2017, asserting race discrimination, age discrimination, and retaliation claims under federal, New York State, and New York City laws. In an earlier order, the court granted defendants’ motion to dismiss in part and denied it in part. That order dismissed all claims except Williams’s claim that she was discriminated against in her termination or demotion from the P.S. 30M kindergarten position when she allegedly was entitled to return for the 2014–15 school year. The remaining claim was adequately pleaded against the Department of Education under the Age Discrimination in Employment Act and against Stinson under New York State and New York City law.

Legal standard

The court applied the summary-judgment standard under Federal Rule of Civil Procedure 56. Summary judgment is proper when the evidence shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. The court must view the evidence and reasonable inferences in the light most favorable to the party opposing the motion, but that party must provide specific evidence rather than rely on allegations, speculation, or unsupported conclusions.

For the age-discrimination claims, the court applied the burden-shifting framework from McDonnell Douglas Corp. v. Green. A plaintiff must first establish a basic initial case of discrimination. The employer then must identify a legitimate, nondiscriminatory reason for its action. At the final stage, the plaintiff must present evidence from which a factfinder could conclude that age was the required cause of the action under the federal law, or that there was a causal link between age bias and the decision under the New York City law.

Court’s analysis

The court identified three independent reasons why Williams could not establish the required initial case of age discrimination.

First, the court found that no reasonable factfinder could conclude that Williams had been terminated or demoted. The Department of Education’s assignment records showed that an assignment for the following week was initially entered, briefly marked canceled by an administrator, restored, and then canceled by the substitute teacher using a code that Williams testified was used when a substitute declined an assignment to work at another school. The records also showed that Williams accepted an assignment at another school the next day. The court concluded that the records indicated defendants offered to continue her work at P.S. 30M and that she declined. The court also relied on Stinson’s testimony that the school expected Williams to continue and was surprised when she did not return.

The court rejected Williams’s reliance on being told to take one day off. It found that this could explain why she did not work on one day but did not explain why she declined the assignment for the following week. The court therefore found no genuine dispute that Williams voluntarily left P.S. 30M.

Second, the court found no circumstances supporting an inference of age discrimination. Williams testified that she did not recall Stinson making comments about anyone’s age. The substitute teacher who covered the kindergarten class after Williams left was two years younger than Williams. The court also addressed Williams’s argument that defendants wanted to avoid paying her more because of her years of service. It held that age and years of service are legally distinct, and that ending someone’s work solely because that person had worked more days or years and would therefore receive higher pay is not age discrimination under the federal age-discrimination law.

Third, the court found no evidence that Williams was entitled to the full-time kindergarten position for the 2014–15 school year or that she had applied for it. Defendants presented testimony that all full-time teachers had to use the regular application process. Williams provided no contrary evidence. The court also found that she did not apply for the position, even though her deposition testimony indicated that she could access the application system and had the option to apply. The court concluded that defendants’ failure to hire her for the full-time position could not constitute age discrimination and that the age of the teacher who was hired could not support an inference of discrimination.

Disposition

Judge Alison J. Nathan granted defendants’ motion for summary judgment. The ruling resolved Williams’s remaining claims under the Age Discrimination in Employment Act, the New York State Human Rights Law, and the New York City Human Rights Law. The clerk was directed to enter judgment and close the case. The court also certified that any appeal would not be taken in good faith and denied Williams permission to appeal without paying court fees.