Brown v. Montefiore Medical Center

Background

Guelda E. Brown, proceeding without a lawyer, sued Montefiore Medical Center, Diane Rodriguez, Aretha Mack, Veronica Crute, Anthony Leung, and Russell Reille. Her amended complaint asserted race, national-origin, religious, and sex-discrimination claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. She also asserted claims concerning medical leave under the Family and Medical Leave Act and state-law claims for assault, negligence, and breach of contract.

The court had previously dismissed Brown’s sex-discrimination claims under Title VII and the two New York human-rights laws, her medical-leave claims, and her assault, negligence, and breach-of-contract claims. In a July 25, 2023 order, the court granted summary judgment—a ruling that there was no legally sufficient factual dispute for a trial—to Montefiore, Mack, Crute, and Leung on Brown’s hostile-work-environment claims under Title VII, § 1981, and the New York State Human Rights Law, and on her retaliation claims under Title VII, § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. The court declined to exercise supplemental jurisdiction over Brown’s hostile-work-environment claim under the New York City Human Rights Law and dismissed that claim without prejudice.

Brown’s response

Rodriguez had not appeared in the case and had not joined the other defendants’ summary-judgment motion. The court therefore ordered Brown to explain why her claims against Rodriguez should not be dismissed. Brown asked that the claims not be dismissed and repeated allegations that Rodriguez questioned and criticized Brown’s religious beliefs, encouraged Mack to act against her, and participated in retaliation after Brown complained to human-resources and compliance personnel. Brown also alleged that Mack called her “Satan” in Rodriguez’s presence and that workplace officials failed to enforce their policies.

Brown identified additional concerns about evidence, including Rodriguez’s personnel file, records of meetings, Rodriguez’s absence from a deposition, Brown’s performance evaluations, and a 2020 settlement conference. The court found that Brown did not explain how these concerns showed that her claims against Rodriguez should continue. It also stated that Brown had responsibility for conducting discovery and presenting evidence needed to oppose summary judgment, even though she was representing herself. The court further found that Brown had not shown that the missing or additional evidence would create a material factual dispute concerning her claims against Rodriguez.

Rulings

The court denied Brown’s request to reconsider the grant of summary judgment to Montefiore, Mack, Crute, and Leung. It stated that Brown had merely repeated arguments made in opposition to summary judgment and had not identified controlling law or facts that the court overlooked and that could reasonably change its decision.

The court then dismissed Brown’s claims against Rodriguez. It relied on its earlier analysis of Rodriguez’s conduct, in which it had concluded that the conduct did not create a hostile work environment or constitute retaliation. The court stated that Brown had not shown that her claims against Rodriguez were plausible or that evidence created a material factual dispute. The order does not state that the dismissal was with or without prejudice. The Clerk was directed to mail the order to Brown and close the case.