Hall v. The Urban Assembly, Inc.

Background

Chad Hall sued The Urban Assembly, Inc., doing business as Urban Assembly School for the Performing Arts, the New York City Department of Education, and the City of New York. He alleged retaliation and interference under the Family and Medical Leave Act (FMLA), based on his termination shortly after he told the school principal that he intended to take additional medical leave.

Hall had worked as an Assistant Dean of Students at the school since October 2012. The opinion describes several earlier disciplinary events, including a 2015 suspension, a 2017 reprimand for lateness, and a February 2018 reprimand for handling a student’s hat. That reprimand warned that similar conduct could result in suspension without pay or termination.

In September 2018, Hall had an altercation with a student while distributing cell phones. The school investigated and concluded on October 19, 2018, that Hall had verbally abused a student. On October 24, school administrators consulted the Department of Education’s legal department and were advised to draft a termination letter. The principal then went on maternity leave, and the letter was not delivered. After returning on January 2, 2019, the principal contacted the Department of Education about completing the termination. The termination letter was finalized by January 23, 2019.

Separately, Hall had taken medical leave related to injuries from a car accident and later surgeries. On January 18, 2019, he discussed a doctor’s letter with the principal. When asked whether he intended to go out on disability, Hall said that he did and was asked to keep the principal informed. Hall was formally terminated five days later, on January 23, 2019.

Legal standard

The court applied the summary-judgment standard under Rule 56 of the Federal Rules of Civil Procedure. Summary judgment is appropriate when the evidence shows no genuine dispute over a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The court must view the evidence in the light most favorable to the party opposing the motion.

Court’s analysis

The FMLA gives eligible employees a right to take up to twelve workweeks of unpaid leave each year for certain serious health conditions. It also prohibits employers from interfering with that right or retaliating against an employee for exercising or attempting to exercise it.

Hall asserted both types of FMLA claims. For retaliation, he had to show that he engaged in FMLA-protected activity, suffered an adverse employment action, and that the action occurred under circumstances suggesting retaliation. For interference based on termination, he had to show that his taking or intending to take FMLA-protected leave was at least a factor in the termination decision.

The court held that Hall could not prove causation for either claim. It found that the undisputed evidence showed the defendants had decided to terminate him as early as October 2018, and no later than January 4, 2019. That was before Hall allegedly told the principal on January 18 that he intended to take additional medical leave. The court concluded that the later timing of the termination did not establish that Hall’s leave-related conduct caused the decision, because the termination plan was already in motion.

The court rejected Hall’s argument that administrators’ alleged complaints between October and December 2018 were retaliatory. Those events occurred before Hall allegedly requested additional FMLA leave. The court also concluded that evidence about a supposedly similarly situated teacher would not change the result. In addition, the court found that Hall’s account of that teacher’s conduct was based on inadmissible hearsay and therefore could not defeat summary judgment.

The opinion also states that Hall conceded his claims against the City of New York were subject to dismissal for a separate reason: the City and the Department of Education are separate legal entities, and Hall did not allege that the City itself took any action.

Disposition

The court granted the defendants’ motion for summary judgment. It directed the Clerk of Court to enter judgment for the defendants on all claims, terminate the motion, and close the case.