Singhal v. Doughnut Plant, INC.

Background

Anjali Singhal sued Doughnut Plant, Inc., Doughnut Plant Management Inc., The International Donut Plant LLC, and Mark Isreal. She alleged claims under Title VII of the Civil Rights Act, the Family and Medical Leave Act, the New York State Human Rights Law, and the New York City Human Rights Law. Her claims included pregnancy, sex, gender, and familial-status discrimination; interference; retaliation; and wrongful termination.

Singhal alleged that Doughnut Plant hired her as Chief Management Officer and General Counsel after she had served as its outside legal counsel. Although the company paid her through an incorporated entity called Singhal & Associates and required weekly timesheets, she alleged that the arrangement was temporary and that benefits would accrue retroactively. She also alleged that she had a company email address, a desk and key card at the company’s office and bakery, access to retail-store offices, and reported daily to Isreal.

On February 14, 2018, Singhal told Isreal that she was pregnant and would need parental leave. She alleged that Isreal responded that he could no longer afford to pay her, then said she could work only on specific urgent matters after she objected that pregnancy-based termination would be unlawful. She later alleged that she experienced reduced duties, hours, and pay; exclusion from meetings; removal of responsibilities; and withholding of information. After she complained to the company’s human-resources coordinator about discriminatory treatment, she alleged that the discrimination and harassment intensified. Defendants terminated her employment on May 4, 2018.

Legal standard

The defendants moved to dismiss the amended complaint under Rule 12(b)(6), which asks whether the complaint states a legally sufficient claim. At this stage, the court accepted well-pleaded factual allegations as true and drew reasonable inferences in Singhal’s favor.

Claims allowed to proceed

The court rejected the defendants’ argument that Singhal was an independent contractor. Whether someone is an employee under Title VII is a fact-intensive question. The court found that her allegations about her hiring, company access, assigned workspace, and daily reporting to Isreal plausibly showed an employment relationship.

The court also found that Singhal adequately pleaded discrimination claims against Doughnut Plant under Title VII and against the defendants under the New York State and New York City Human Rights Laws. The allegations that she was pregnant, qualified for her position, suffered termination, and experienced circumstances suggesting discrimination were sufficient at the motion-to-dismiss stage.

The court allowed the retaliation claims to proceed because Singhal alleged that she made a discrimination complaint, the defendants knew about it, she experienced adverse treatment including termination, and the timing supported a connection between her complaint and the defendants’ actions.

The court also allowed the New York City Human Rights Law interference claim to proceed. Singhal alleged that the defendants threatened to challenge her law license and that Isreal physically blocked her office while speaking in a threatening tone. The court held that these allegations sufficiently pleaded threats, an element of the interference claim.

The court further allowed the pregnancy-accommodation claim under New York City’s Pregnant Workers Fairness Act to proceed. It held that termination in response to repeated requests for maternity leave could be viewed as denial of a reasonable accommodation that would facilitate childbirth.

Claims dismissed

The court dismissed the Family and Medical Leave Act claims because the amended complaint did not allege that the defendants employed at least 50 employees or that Singhal had worked at least 1,250 hours during the relevant period.

The court dismissed the New York State and New York City aiding-and-abetting claims as duplicative. It reasoned that Isreal could not aid and abet his own alleged conduct, and that the corporate defendants could not be liable for aiding and abetting their own conduct or Isreal’s conduct under the allegations presented.

The court dismissed the New York City Human Rights Law vicarious-liability claim against Isreal as abandoned because Singhal did not defend it in her opposition. It dismissed the same claim against Doughnut Plant as duplicative because the court allowed separate, non-derivative New York City Human Rights Law claims against that defendant to continue.

The court dismissed the Pregnant Workers Fairness Act claim alleging discrimination and termination as duplicative and moot because Singhal had separately pleaded a pregnancy-discrimination claim under the New York City Human Rights Law. The court did not dismiss her separate reasonable-accommodation claim.

Finally, the court dismissed the negligence claim because it was based on the same alleged intentional conduct underlying the discrimination, retaliation, and accommodation claims.

Disposition

Judge Andrew L. Carter, Jr. ordered that the defendants’ motion to dismiss was granted in part and denied in part. The motion was denied as to the First, Second, Fifth, Sixth, Eighth, Ninth, Eleventh, and Fourteenth Causes of Action, and granted as to the Third, Fourth, Seventh, Tenth, Twelfth, Thirteenth, and Fifteenth Causes of Action. The court directed the parties to submit a joint status letter within fourteen days and directed the clerk to terminate the motion.