Zoulas v. Department of Education
- Gregory Woods
- 1:18-cv-02718
- U.S. District Court · Southern District of New York
- 2
In Zoulas v. New York City Department of Education, Judge Woods granted summary judgment to the Department on all three age-discrimination claims.
Peggy Zoulas and the New York City Department of Education; the judgment resolved Zoulas’s three age-discrimination claims and closed the case.
What happened
Peggy Zoulas sued the New York City Department of Education under the Age Discrimination in Employment Act, bringing claims for age discrimination, retaliation, and a hostile work environment.
The court ruled that Zoulas had not provided enough evidence for a reasonable jury to find in her favor. It held that her discrimination claim was time-barred, and that her retaliation and hostile-work-environment claims lacked evidence creating a genuine factual dispute.
Judge Woods granted the Department’s motion for summary judgment on all three claims. The court entered judgment for the Department, closed the case, and denied fee-free appeal status because an appeal would not be taken in good faith.
The detailed version
- Zoulas v. Department of Education · No. 1:18-cv-02718
- Gregory Woods
- Sept. 2, 2021
Background
Peggy Zoulas brought three claims against the New York City Department of Education under the Age Discrimination in Employment Act: age discrimination, retaliation, and hostile work environment. The judgment states that the court relied on its memorandum opinion and order dated September 1, 2021.
Court’s Analysis
The court granted the Department’s motion for summary judgment on all three claims. Summary judgment is a decision entered when the evidence does not present a genuine dispute that requires a trial.
For the age-discrimination claim, the court stated that Zoulas had not provided evidence that she suffered an adverse employment action within the 300 days before filing her complaint with the New York State Division of Human Rights. The court therefore held that the claim was time-barred.
For the retaliation claim, the court stated that Zoulas had not provided evidence from which a reasonable jury could conclude that, after she filed her Division of Human Rights complaint, she experienced conduct that would discourage a reasonable person from filing such a complaint. The court found that she had not shown a genuine issue of material fact on that claim.
For the hostile-work-environment claim, the court stated that Zoulas had not provided evidence from which a reasonable jury could conclude that she experienced hostile and pervasive abuse or harassment based on her age that changed the terms of her employment. The court found that she had not shown a genuine issue of material fact on that claim either.
Disposition
Judge Gregory Woods granted the New York City Department of Education’s motion for summary judgment on all three claims. The court entered judgment for the Department and closed the case. It also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free appeal status for that purpose.
The supplied case metadata identifies Gregory Woods as the judge, while the provided judgment itself is signed by the clerk and does not name the judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.
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