Singh v. Knuckles, Komosinski & Manfro, LLP

Background

Mandip Singh brought claims against her former employer, Knuckles, Komosinski & Manfro, LLP (KKM), and Debbie Bhoorasingh, individually. She alleged that the defendants violated Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law by terminating her because of her pregnancy and gender.

Singh began working for KKM on October 31, 2016, as a clerk in the Evictions Department. She was reassigned to the Foreclosure Sales Department on January 10, 2017. The parties disputed the reason for that reassignment. Bhoorasingh said it resulted from workplace issues, absences, and delays in completing work; Singh testified that she had not experienced problems with coworkers and had volunteered to help in the Sales Department.

The parties also disputed the significance of Singh’s later absences, her work performance, and the steps KKM took after she disclosed her pregnancy. Singh told Bhoorasingh that she was pregnant on May 25, 2017. Five days later, Bhoorasingh emailed Knuckles and Jordan Manfro that Singh was not completing assigned work and that KKM needed to address the situation. Knuckles responded, “We have to terminate Mandip.”

After Singh reported that she had been placed on bed rest, Bhoorasingh emailed Knuckles that KKM needed to terminate her as soon as possible. KKM later required Singh to provide additional medical information and sign a patient authorization form before returning to work. Singh returned after KKM received a letter stating that she could work without accommodations. KKM terminated her employment on July 21, 2017, after she reported that she was not feeling well and would not come to work that day.

The defendants maintained that Singh was terminated because she could not attend work consistently, did not complete assignments on time, and caused KKM to reassign employees to complete her duties. Singh disputed that explanation and testified that the defendants’ treatment of her changed after she disclosed her pregnancy.

Summary-judgment standard

The defendants moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is appropriate only when there is 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 favorably to the party opposing the motion, but that party cannot rely only on conclusory allegations or speculation.

Title VII claim

The court applied the burden-shifting framework used in employment-discrimination cases. First, a plaintiff must make a basic showing that she was in a protected category, was qualified for the job, suffered an adverse employment action, and was terminated under circumstances suggesting discrimination. The employer then must identify a legitimate, nondiscriminatory reason for the action. The plaintiff may survive summary judgment by presenting evidence from which a reasonable factfinder could conclude that the stated reason was a pretext, or that discrimination was a motivating factor.

The court found that Singh met the initial qualification requirement. The court emphasized that the threshold is low and that the parties agreed she was capable of doing the work when present. The court also noted testimony from Knuckles that Singh was smart and could do the job, and testimony from Bhoorasingh that Singh could perform the work when she was present.

The court further found circumstances supporting an inference of discrimination. KKM discussed terminating Singh two workdays after learning of her pregnancy, and Bhoorasingh discussed termination shortly after learning that Singh had been placed on pregnancy-related bed rest. Singh also testified that Bhoorasingh’s treatment of her changed after she announced her pregnancy.

The court accepted that KKM had provided a legitimate, nondiscriminatory explanation based on Singh’s absences, missed deadlines, and possible interpersonal problems. But it found a genuine dispute about whether that explanation was pretextual or whether pregnancy was an impermissible motivating factor. The court identified the timing of the termination discussions, the wording of the defendants’ emails, inconsistencies concerning Singh’s earlier reassignment, evidence of changed expectations after her pregnancy announcement, and the medical-authorization requirement as evidence a reasonable jury could consider.

New York claim

The court stated that Singh’s New York State Human Rights Law claims were analyzed in the same way as her Title VII claims. Because the evidence created a factual dispute under the Title VII analysis, the court applied that analysis to the state-law claims as well.

Ruling

Judge Nelson S. Roman denied the defendants’ motion for summary judgment. The court directed the Clerk to terminate the motion at ECF No. 36 and noted that a pretrial conference was scheduled for January 13, 2021. The opinion did not decide whether the defendants actually discriminated against Singh; it held that the evidence was sufficient for the claims to proceed beyond summary judgment.