Shkreta v. Colonnade Management Corporation
- Ronnie Abrams
- 1:20-cv-06134
- U.S. District Court · Southern District of New York
- 2
In Shkreta v. Colonnade Management Corporation, Judge Abrams denied as moot the motion on the family-leave claim and dismissed the city human-rights claim for lack of supplemental jurisdiction.
Xhejni Shkreta’s Family and Medical Leave Act claim had already been voluntarily dismissed, and her New York City Human Rights Law claim was dismissed for lack of supplemental jurisdiction. The defendants’ request for summary judgment on the Family and Medical Leave Act claim was denied as moot. The order does not resolve the remaining Fair Labor Standards Act or New York Labor Law claims.
What happened
In Shkreta v. Colonnade Management Corporation, Xhejni Shkreta brought claims under federal wage and family-leave laws, New York’s labor law, and New York City’s human-rights law. The defendants asked for judgment on the family-leave claim and the city human-rights claim.
The parties later agreed to dismiss the family-leave claim, so the court treated the defendants’ request for judgment on that claim as moot. Shkreta also asked the court to dismiss her city human-rights claim because the court lacked authority to hear it alongside her remaining federal wage claim.
Judge Ronnie Abrams agreed that the city human-rights claim was connected to the federal wage claim only by the parties’ employment relationship and dismissed it for lack of supplemental jurisdiction. The court denied the defendants’ motion for summary judgment on the family-leave claim as moot.
The detailed version
- Shkreta v. Colonnade Management Corporation · No. 1:20-cv-06134
- Ronnie Abrams
- Jan. 26, 2022
Background
Xhejni Shkreta sued Colonnade Management Corporation, Columbus Properties, Inc., and John DiMurro. She asserted claims under the Fair Labor Standards Act, a federal wage law; the Family and Medical Leave Act; the New York Labor Law; and the New York City Human Rights Law.
The defendants filed a motion for partial summary judgment and partial judgment on the pleadings. They sought summary judgment on the Family and Medical Leave Act claim and judgment on the pleadings on the New York City Human Rights Law claim.
Family and Medical Leave Act Claim
After the defendants filed their motion, the parties stipulated to voluntarily dismiss the Family and Medical Leave Act claim. Shkreta acknowledged that she had agreed to its dismissal. Because that claim had already been dismissed, the court denied the defendants’ motion for summary judgment on it as moot.
New York City Human Rights Law Claim
Shkreta asked the court to dismiss her New York City Human Rights Law claim for lack of supplemental jurisdiction. Supplemental jurisdiction is a court’s authority to hear a state or local claim together with a related federal claim. The court agreed that the human-rights claim had no connection to Shkreta’s Fair Labor Standards Act claim beyond the existence of a common employment relationship. The opinion describes the human-rights claim as alleging that Shkreta was terminated because of her pregnancy and anticipated maternity leave.
The court therefore dismissed Shkreta’s New York City Human Rights Law claim for lack of supplemental jurisdiction. The order does not state a disposition of the remaining Fair Labor Standards Act or New York Labor Law claims. The Clerk was directed to terminate the motion at docket number 32.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.