Williams-Lawson v. Subway Surface Supervisors Association
- Paul Gardephe
- 1:20-cv-08544
- U.S. District Court · Southern District of New York
- 5
In Williams-Lawson v. Subway Surface Supervisors Association, Judge Gardephe granted summary judgment on federal claims and dismissed state and city claims without prejudice.
Yvette Williams-Lawson’s federal discrimination claims were resolved against her through summary judgment, while her New York State and New York City claims were dismissed without prejudice. The defendants received summary judgment on the federal claims.
What happened
Yvette Williams-Lawson, representing herself, sued Subway Surface Supervisors Association, Michael Carrube, and William Torres, alleging discrimination based on sex, race, and religion, retaliation, termination, and harassment. She brought claims under federal, New York State, and New York City laws.
The court adopted Magistrate Judge Sarah L. Cave’s recommendation after no party objected. It granted the defendants summary judgment on Williams-Lawson’s Title VII and Section 1981 claims. The court concluded that the Title VII claims were filed too late and that the Section 1981 claims lacked sufficient support for discrimination, retaliation, or a hostile work environment.
Judge Gardephe dismissed Williams-Lawson’s New York State and New York City Human Rights Law claims without prejudice because the federal claims had failed and the court declined to decide the remaining state and city claims. The court closed the case.
The detailed version
- Williams-Lawson v. Subway Surface Supervisors Association · No. 1:20-cv-08544
- Paul Gardephe
- Sept. 20, 2021
Background
Yvette Williams-Lawson sued Subway Surface Supervisors Association, Michael Carrube, identified as the Association’s president, and William Torres, identified as its secretary/treasurer. Williams-Lawson alleged discrimination based on sex, race, and religion, termination of her employment, retaliation, and a hostile work environment. She asserted claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. The opinion describes her as the Association’s executive vice president and says that the Association’s members elected her to that position.
The defendants moved to dismiss or, alternatively, for summary judgment. Summary judgment asks the court to resolve claims based on the written record rather than holding a trial. The court referred the motion to Magistrate Judge Sarah L. Cave, who converted the motion to one for summary judgment and issued a report and recommendation advising that the motion be granted.
Court’s Review
No party objected to the report and recommendation. Because the parties had been told that failing to object would waive appellate review, Judge Gardephe reviewed the recommendation for clear error, meaning an obvious mistake in the record. He found no clear error and adopted the recommendation.
Federal Claims
The court granted the defendants summary judgment on Williams-Lawson’s Title VII claims because they were untimely. The complaint was filed on October 9, 2020, more than seven months after Williams-Lawson received the Equal Employment Opportunity Commission’s March 3, 2020 right-to-sue letter, which stated that a lawsuit had to be filed within 90 days.
The court also granted the defendants summary judgment on the claims under 42 U.S.C. § 1981. As to discrimination, the court agreed that Williams-Lawson had not provided evidence that similarly situated employees were treated differently. As to retaliation, the court agreed that she had not shown that she engaged in protected activity or that the alleged protected activity was close enough in time to the alleged adverse actions. As to hostile work environment, the court agreed that the alleged discriminatory conduct was not sufficiently severe or pervasive to change her working conditions or create an abusive workplace.
State and City Claims
The court dismissed Williams-Lawson’s New York State Human Rights Law and New York City Human Rights Law claims without prejudice. It declined to exercise supplemental jurisdiction, meaning authority to decide related state and city claims, after the federal claims failed.
Disposition
The report and recommendation was adopted. The defendants were granted summary judgment on the Title VII and Section 1981 claims. The New York State and New York City claims were dismissed without prejudice. The clerk was directed to terminate the motion and close the case.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.