Doyle v. Mid-Hudson Valley Federal Credit Union

Background

Diane Doyle sued Mid-Hudson Valley Federal Credit Union under the federal Age Discrimination in Employment Act and the New York State Human Rights Law. She alleged that the credit union terminated her because of her age and requested liquidated, compensatory, and punitive damages.

Doyle had worked for the credit union since April 2012 as the branch manager of its Middletown branch. The credit union terminated her on April 26, 2019, and hired Denise Romero, who was 35 at the time, to replace her.

The parties disputed the events leading to Doyle’s termination. The credit union claimed that Doyle pressured employees to open new membership accounts, instructed an employee to violate account-opening procedures, and tried to cover up that employee’s forgery of his sister’s signature. Doyle denied pressuring employees or participating in a cover-up. The parties also disputed when Doyle discovered the forgery and how quickly she reported it.

Doyle supported her discrimination claims with evidence that Christopher Gomez, the credit union’s Senior Vice President and Chief Retail Officer, made derogatory comments about older employees, questioned her or others about retirement, interacted more meaningfully with younger employees, and sought to remove older employees. Another employee, Marcie Tuey-Bigelow, testified about Gomez’s alleged comments and conduct. The credit union denied that age influenced its employment decisions, and Gomez denied making derogatory comments or discriminating against older employees.

Legal standard

The credit union moved for summary judgment under Rule 56. Summary judgment is appropriate when the evidence shows that no genuine dispute exists about a fact important to the case and the moving party is entitled to judgment as a matter of law. At this stage, the court does not decide which witnesses are truthful or weigh the evidence; it asks whether a reasonable jury could decide for the nonmoving party.

The court applied the framework used for age-discrimination claims under both the federal law and the New York law. Under that framework, an employer must give a legitimate, nondiscriminatory reason for its action if the employee establishes an initial showing of discrimination. The employee may then show that the employer’s stated reason was a pretext—a false explanation used to conceal discrimination.

Court’s analysis

The court assumed that Doyle had made the required initial showing and found that the credit union had offered legitimate, nondiscriminatory reasons for terminating her: allegedly excessive pressure on staff, authorization of an account opened contrary to credit union procedures, and an attempted cover-up of the forgery.

The court held that Doyle nevertheless raised a material factual question about whether those reasons were pretextual. It relied on the evidence concerning Gomez’s alleged age-related comments and conduct, Tuey-Bigelow’s testimony supporting Doyle’s account, and the undisputed fact that Doyle was replaced by a substantially younger employee. Because a reasonable jury could find that age discrimination caused Doyle’s termination, the court declined to resolve the disputed facts on summary judgment.

Disposition

The court denied Mid-Hudson Valley Federal Credit Union’s motion for summary judgment on Doyle’s age-discrimination claims under the Age Discrimination in Employment Act and the New York State Human Rights Law. The parties were directed to appear for a telephonic pretrial status conference on September 14, 2023.