Symotyuk-Knoll v. HealthEquity, Inc.

Background

Victoria Symotyuk-Knoll sued her former employers, HealthEquity, Inc. and WageWorks, Inc., alleging discrimination and retaliation based on sex, age, caregiver status, and pregnancy. She alleged that she requested leave under the Family and Medical Leave Act (FMLA), later sought intermittent leave under New York law, and was laid off shortly after returning from FMLA leave. She claimed the defendants actually terminated her because of her pregnancy, leave, expected caregiving responsibilities, and age. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which concerns subject-matter jurisdiction, and Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim.

Court’s analysis

The court held that it lacked subject-matter jurisdiction over Symotyuk-Knoll’s New York State Human Rights Law (NYSHRL) claims under New York’s election-of-remedies rule. She had filed those claims with the New York State Division of Human Rights, and that agency had not dismissed her complaint in a way that would allow the claims to proceed in federal court. The court therefore dismissed the NYSHRL claims without prejudice under Rule 12(b)(1).

The court dismissed the discrimination claims under Rule 12(b)(6). Although Symotyuk-Knoll alleged that she was qualified and that her termination was an adverse employment action, the court found that she had not pleaded enough facts connecting the termination to discrimination. In particular, the court found that her comparisons to other employees were insufficient, her allegations about a training exclusion were speculative, and comments about childcare and leave did not adequately show discriminatory intent. The court also dismissed the hostile-work-environment claim because the alleged comments and conduct were not sufficiently severe or pervasive and did not show that the conduct unreasonably interfered with her work.

The court dismissed the FMLA interference claim because Symotyuk-Knoll received twelve weeks of FMLA leave and later took intermittent leave. The court found that she had not adequately alleged that the continued delegation of some responsibilities to another employee during her intermittent leave violated her FMLA rights or caused the required prejudice. By contrast, the court held that the retaliation allegations could proceed. For purposes of the motion, it accepted that seeking pregnancy leave was protected activity, that the defendants knew about it, and that Symotyuk-Knoll was terminated because of that activity. The court also found that she adequately pleaded retaliation under the New York City Human Rights Law’s more lenient standard.

Disposition

The court partially granted the defendants’ motion to dismiss. It granted the motion under Rule 12(b)(6) as to the hostile-work-environment, discrimination, and FMLA interference claims and dismissed those claims with prejudice. It denied the motion as to the retaliation claims. It dismissed the NYSHRL claims without prejudice under Rule 12(b)(1) for lack of subject-matter jurisdiction. Judge Andrew L. Carter, Jr. signed the order.