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S.D.N.Y.MixedFiled Mar. 31, 2022

Branch v. State University of New York Downstate Medical Center

Judge
Analisa Torres
Docket
1:18-cv-09516
Court
U.S. District Court · Southern District of New York
Pages
2
EmploymentSummary JudgmentCivil Procedure
In one sentence

In Branch v. State University of New York Downstate Medical Center, Judge Torres granted defendants’ summary judgment on discrimination claims, dismissed NYCHRL claims, and denied Branch’s letter-brief motion.

Who this affects

Romain R. Branch, the State University of New York Downstate Medical Center, and Ayman Fanous; the order granted defendants’ summary judgment on several discrimination claims and dismissed Branch’s New York City Human Rights Law claims.

What happened

In Branch v. State University of New York Downstate Medical Center, Romain R. Branch sued the State University of New York Downstate Medical Center and Ayman Fanous, alleging employment discrimination under federal, state, and New York City laws. The court had previously dismissed several claims and left disparate-treatment claims and claims under the New York City Human Rights Law for further proceedings.

The court granted defendants’ motion for summary judgment on Branch’s disparate-treatment claims under Title VII, Sections 1981 and 1983, and the New York State Human Rights Law. The court dismissed Branch’s New York City Human Rights Law claims because it declined to continue exercising supplemental jurisdiction over them. The court also denied Branch’s motion to file a supplemental letter brief.

Judge Analisa Torres ruled that there were no genuine disputes of material fact and that defendants were entitled to judgment as a matter of law on the disparate-treatment claims. The order stated that the court would later issue a memorandum opinion addressing defendants’ motion.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Branch v. State University of New York Downstate Medical Center · No. 1:18-cv-09516
Judge
Analisa Torres
Date
Mar. 31, 2022

Background

Romain R. Branch brought claims against the State University of New York Downstate Medical Center and Ayman Fanous, individually and as chair of the Department of Psychiatry, alleging employment discrimination. The claims arose under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 1981 and 1983, the New York State Human Rights Law, and the New York City Human Rights Law.

The court had previously granted defendants’ motion to dismiss Branch’s retaliation and hostile-work-environment claims under Title VII, Sections 1981 and 1983, and the New York State Human Rights Law. It also granted the motion as to Branch’s New York City Human Rights Law claims against Fanous in his individual capacity. The court denied the motion as to Branch’s disparate-treatment claims under Title VII, Sections 1981 and 1983, and the New York State Human Rights Law, and as to his New York City Human Rights Law claims against the State University of New York Downstate Medical Center.

Rulings

Defendants moved for summary judgment on the remaining claims. Summary judgment is a decision entered when the court finds there is no genuine dispute over a fact important to the case and that one side is entitled to judgment under the law. The court found no genuine disputes of material fact and held that defendants were entitled to judgment as a matter of law on Branch’s disparate-treatment claims under Title VII, Sections 1981 and 1983, and the New York State Human Rights Law. The court therefore granted defendants’ motion for summary judgment on those claims.

The court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims in the same case—over Branch’s New York City Human Rights Law claims. It therefore dismissed those claims. The opinion does not state whether that dismissal was with or without prejudice.

The court also denied Branch’s motion for leave to file a supplemental letter brief. It directed the Clerk of Court to terminate the motions at ECF Nos. 173 and 204 and stated that it would later issue a memorandum opinion addressing defendants’ motion.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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