Teachey v. Equinox Holdings, Inc.

Background

Gregory Teachey sued his former employer, Equinox Holdings Inc., alleging that Equinox terminated him because of his age. He brought claims under the Age Discrimination in Employment Act, a federal law protecting employees age 40 and older, and the New York City Human Rights Law. Equinox moved for summary judgment, asking the court to dismiss the complaint without a trial.

Teachey was 50 when Equinox hired him as a Front Desk Associate in late February 2017. The opinion states that most front-desk employees were in their 20s or 30s. In January, Teachey was disciplined after managers saw him out of uniform, without a nametag, and sitting on top of the front desk. The opinion states that he was not terminated for that incident alone.

The second incident involved a member and guest who entered the gym without, according to Equinox, completing the required check-in process. Teachey maintained that he was not at the front desk when they entered and believed they had already been checked in. After the incident, Equinox managers decided to terminate his employment rather than issue another disciplinary write-up.

Evidence considered

The court did not consider a declaration from former coworker Michael Shkreli as substantive support for Teachey’s opposition. The court explained that Shkreli had stated he did not remember the declaration or the events described in it and would not testify consistently with it at trial. The court therefore concluded that the declaration could not be used substantively at the summary-judgment stage.

The court did consider Teachey’s evidence of age-related comments by Equinox employees and managers. The reported comments included statements that Teachey was too old for the front desk, references to his being approximately 50, and a statement by supervisor Adam Gecht that Teachey was too old and should not be making mistakes at the front desk. Equinox disputed these allegations.

Legal standard

Summary judgment is appropriate only when the evidence shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. The court must view the evidence favorably to the party opposing the motion. In an employment-discrimination case, the court must determine whether the evidence could allow a reasonable jury to find that the employer’s stated reason was not the real reason and that discrimination motivated the action.

ADEA claim

The court assumed, for purposes of the motion, that Teachey could establish the initial elements of an age-discrimination claim. Equinox offered a legitimate, nondiscriminatory explanation for the termination: two policy violations close together, involving the dress code and the guest-check-in policy.

The court nevertheless concluded that a reasonable jury could find this explanation was pretextual. First, the court rejected Equinox’s reliance on the “same actor” inference—the idea that a person who helped hire an employee would be less likely to later fire that employee because of the same protected characteristic. The court noted that the evidence could support a finding that Mongiovi did not know Teachey’s age when he was hired and learned it during onboarding. The court also noted evidence that Teachey may have been hired because Equinox was especially short-staffed, which could allow a jury to find that the circumstances later changed.

Second, the court held that the lack of evidence about younger employees who violated the guest policy did not by itself defeat Teachey’s claim. A discrimination plaintiff does not always need to identify a younger employee who was treated more favorably.

Third, the court found evidence from which a jury could question whether the guest-policy violation was genuinely the reason for the termination. Teachey testified that he asked Equinox to investigate which coworkers were at the front desk when the member and guest arrived and that Gecht responded that it was not important. The court stated that a jury could infer from this response and the lack of a full investigation that Equinox used the incident as an excuse rather than as the true basis for the termination.

The court also rejected Equinox’s argument that the age-related comments were merely irrelevant “stray remarks” or neutral references to age. Viewed together and in context, the court concluded, the comments by managers involved in the termination could support an inference of age-based bias. The court therefore held that Equinox was not entitled to summary judgment on the ADEA claim.

New York City Human Rights Law claim

The court also denied summary judgment on Teachey’s New York City Human Rights Law claim. It reasoned that the city law provides protection at least as broad as the federal and state standards relevant here, so the same evidence that defeated summary judgment on the ADEA claim also defeated summary judgment on the city-law claim.

Disposition

The court denied Equinox’s motion for summary judgment and directed the Clerk of Court to close the motion on the docket. The opinion did not decide whether Teachey ultimately proved age discrimination.