Taylor v. City of New York

Background

Stanley Taylor sought a sanitation-worker position with the New York City Department of Sanitation (DSNY). He passed the civil-service examination, later became medically qualified, completed DSNY’s commercial driver’s-license training, and was eligible for the 2015 training class. The parties agreed that candidates became DSNY employees on the first day of training.

At a DSNY orientation, staff told Taylor to complete a Comprehensive Personnel Document (CPD). Taylor said he tried but could not complete it electronically. He was already working for another City agency and completed an Update Personnel Document (UPD). The parties disputed whether an existing City employee like Taylor had to complete a new CPD.

Taylor later met with Nancy A. Reilly, then DSNY’s Director of Human Resources. Taylor testified that Reilly said, we don’t need people like you and black people aren’t dependable. Reilly denied making those statements. Reilly instructed Taylor to complete the CPD by 4:00 p.m. that day. Taylor said he could access the form but could not add information because he was already a City employee. DSNY then reported him as having failed to report and gave his position to the next candidate.

Taylor’s remaining claims were race discrimination under Title VII of the Civil Rights Act of 1964 and race discrimination under 42 U.S.C. § 1981. The defendants moved for summary judgment, asking the court to rule that no genuine dispute of important fact required a trial.

Title VII Claim

The court denied summary judgment on Taylor’s Title VII claim. Title VII prohibits an employer from refusing to hire someone because of race. The court found that Taylor presented evidence supporting each part of an initial race-discrimination showing: he is African American, was qualified, was denied the position, and was rejected under circumstances supporting an inference of discrimination.

The court treated Taylor’s testimony about Reilly’s alleged statements as sufficient to support that initial showing. Reilly’s denial created a factual dispute for a jury rather than a basis for summary judgment. The court also rejected the defendants’ argument that the statements were unrelated stray comments because Reilly was the decision-maker, the comments concerned race, and they were made during the hiring-related interaction.

The defendants offered Taylor’s failure to complete the CPD as a legitimate, nondiscriminatory reason for refusing to hire him. The court found a genuine factual dispute about that reason because the CPD form submitted by the defendants said the form might not be required for a current City employee and instructed such an employee to complete a UPD instead. Taylor was already working for the City and had completed a UPD. The court therefore concluded that it could not decide at summary judgment whether the CPD requirement was a valid reason for the decision.

Section 1981 Claim

The court granted summary judgment on Taylor’s Section 1981 claim. Because the claim was against municipal defendants, Taylor generally had to show that the alleged violation resulted from a City policy or custom. A single act could support municipal liability if committed by an official with final authority to make policy.

The court found no evidence of an official policy or custom of race discrimination and no evidence that Reilly was a final policymaker. The court also rejected Taylor’s argument that the City could be held responsible simply because Reilly was its employee. The court concluded that an individual employee’s isolated act, without final policymaking authority, did not represent official City policy for purposes of this claim.

Disposition

Judge Mary Kay Vyskocil denied in part and granted in part the defendants’ motion for summary judgment. The motion was denied as to Taylor’s Title VII race-discrimination claim and granted as to his Section 1981 claim. The opinion does not state a separate disposition for the age-discrimination and retaliation claims mentioned in the earlier procedural history.