Washington v. NYC Madison Avenue Medical P.C.

Background

Stacy Washington worked as a receptionist for NYC Madison Avenue Medical P.C. from October 2017 until May 6, 2019. She alleges that NYC Madison and her supervisor, Eliz Cruz, discriminated against her because of her pregnancy and retaliated against her for requesting and taking maternity leave. Her claims included federal discrimination and retaliation claims under Title VII of the Civil Rights Act of 1964, discrimination and retaliation claims under the New York City Human Rights Law, a claim against Cruz for aiding and abetting discrimination, and a claim against NYC Madison for employer liability under the city law.

NYC Madison moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is a decision without a trial that is appropriate only when there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law.

Court’s Reasoning

For the Title VII pregnancy-discrimination claim, the court applied the three-step framework requiring a plaintiff first to show circumstances supporting an initial inference of discrimination, after which the employer must give a legitimate, nondiscriminatory reason for its action, and the plaintiff must then present evidence that the reason was a pretext, or cover, for discrimination.

The court held that Washington met the initial burden based on the timing of events. Cruz’s documented knowledge of Washington’s pregnancy was followed by work warnings before maternity leave, and Washington was fired five days after returning from leave. NYC Madison offered alleged poor performance and repeated warnings as its legitimate reason for the termination.

The court nevertheless found genuine disputes about whether that reason was pretextual. Washington disputed the alleged performance problems and Cruz’s treatment of her after learning about the pregnancy. She also asserted that Cruz did not provide leave paperwork until Washington sought help from another administrator and that a warning was issued on the same day she received the paperwork. In addition, Washington challenged six of seven medical-imaging records that NYC Madison relied on. Some were dated during her maternity leave or after her termination, one was typewritten even though she testified that she did not type those forms, and she testified that she did not recognize or use certain forms.

Because the New York City Human Rights Law is interpreted more broadly than federal discrimination law, the court concluded that the same factual disputes also prevented summary judgment on Washington’s city-law discrimination claim. As to the retaliation claims, NYC Madison had not submitted discussion, argument, or legal authority showing that those claims were insufficient. The court therefore denied summary judgment on the Title VII retaliation claim and the city-law retaliation and employer-liability claim. The opinion did not rule on Washington’s separate aiding-and-abetting claim against Cruz through this motion.

Disposition and Further Proceedings

The court denied NYC Madison’s motion for summary judgment in its entirety. The order resolved docket entry 58. The court stated that the parties would be referred to mediation by separate order and required a joint status report addressing whether and to what extent Washington intended to continue pursuing her claims against Cruz. The final pretrial conference was adjourned to October 27, 2023. The opinion was signed by Chief United States District Judge Laura Taylor Swain.