Green v. NYU Langone Medical Center

Background

Memoris Pitter Green sued NYU Langone Medical Center under 42 U.S.C. § 1981, Title VII of the Civil Rights Act, the New York State Human Rights Law, and the New York City Human Rights Law. She alleged race discrimination and retaliation connected to her treatment during her employment as a phlebotomist at NYU’s Outpatient Laboratory, her August 6, 2010 termination, and her treatment after returning to work on November 8, 2010. She also alleged a hostile work environment based on events before her termination and her supervisor’s direction that she sit in a pantry for the entire day after her reinstatement.

Green was reinstated after a grievance proceeding but was not compensated for the time between her termination and reinstatement. She filed an Equal Employment Opportunity Commission charge on April 17, 2012 and filed this lawsuit on April 29, 2015.

Summary-judgment standard

NYU moved for summary judgment under Rule 56 of the Federal Rules of Civil Procedure. Summary judgment is appropriate when the evidence shows that there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The court must view reasonable inferences in favor of the party opposing the motion.

Federal claims

NYU argued, and Green did not dispute, that her federal claims were barred by statutes of limitations. For her Title VII claims, the court applied the rule requiring a discrimination charge to be filed with the Equal Employment Opportunity Commission within 300 days of the challenged employment action because New York has its own antidiscrimination laws and enforcement agency. Green’s termination occurred on August 6, 2010, and the last event supporting her hostile-work-environment claim occurred on November 8, 2010. The court concluded that the deadlines for filing the charge were June 2, 2011, for the discrimination and retaliation claims and September 4, 2011, for the hostile-work-environment claim. Because Green filed her charge on April 17, 2012, the court held that her Title VII claims were untimely and that NYU was entitled to dismissal of those claims as a matter of law.

The court applied a four-year limitations period to Green’s claim under 42 U.S.C. § 1981. Based on the last specified event underlying the hostile-work-environment claim, the court concluded that Green had until November 8, 2014, to file that claim. Because she filed her complaint on April 29, 2015, the court held that the § 1981 claim was untimely and that NYU was entitled to dismissal of that claim as a matter of law.

State and local claims

After dismissing all claims within its original federal jurisdiction, the court considered whether to retain jurisdiction over the New York State and New York City claims. The court explained that supplemental jurisdiction is discretionary and that courts generally decline to keep state-law claims when all federal claims have been eliminated before trial. It concluded that the state and local claims substantially predominated over the federal claims and involved different legal standards, including the New York City Human Rights Law’s independent analysis. Because no independent basis for federal jurisdiction existed, the court declined to exercise supplemental jurisdiction over the remaining state and local claims.

Disposition

Judge Laura Taylor Swain granted NYU’s motion for summary judgment to the extent that Green’s federal claims were dismissed in their entirety. The court declined to exercise jurisdiction over Green’s state and local claims, directed the Clerk of Court to enter judgment accordingly, and closed the case. The order does not state whether the state and local claims were dismissed with or without prejudice; it states only that the court declined supplemental jurisdiction over them.