Carlson v. Northwell Health Inc.

Background

Keith Carlson brought an age-discrimination action against Northwell Health, Inc. He alleged that his supervisor began applying age-based stereotypes to him after learning his age and that Northwell terminated his employment on October 18, 2019, for pretextual reasons. The claims arise under the federal Age Discrimination in Employment Act, the New York State Human Rights Law, and the New York City Human Rights Law.

The Summary-Judgment Motion

Northwell moved for summary judgment, which is a request for judgment without a trial because the moving party claims that no important facts are genuinely disputed. Northwell argued that the evidence showed no material connection between Carlson’s age and the termination decision. It submitted deposition testimony indicating that several Northwell employees had observed and recorded deficiencies in Carlson’s work performance. The court stated that this evidence could support a nondiscriminatory reason for the termination. The court also noted that the supervisor who hired Carlson was the same person who fired him, a fact that strongly weakened an inference of discrimination.

Carlson offered evidence from which a jury could find that Northwell’s stated reason was a pretext, meaning a false explanation masking discrimination. That evidence included a lack of contemporaneous documentation for the alleged performance problems and testimony that his supervisor changed her treatment of him after learning his age and fired him soon afterward.

Ruling

Judge Denise Cote held that the conflicting evidence created material factual disputes for a jury. The court therefore denied Northwell’s motion for summary judgment. The parties were ordered to be prepared to proceed to trial on May 12, 2022.