Cela v. NewYork-Presbyterian Hospital

Background

Klara Cela sued NewYork-Presbyterian Hospital and Della Info Tech Inc. under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. She alleged pregnancy discrimination and retaliation.

Della recruited Cela for a medical assistant position at NewYork-Presbyterian Hospital. Before she began working, Della required her to undergo a medical examination, during which she disclosed that she was pregnant. Cela alleged that the examination results, including information about her pregnancy, were sent to both defendants. She began working on or about November 3, 2021, but her employment ended after three days. Della told her that the reasons were inappropriate long nails, an inability to work independently, and an incorrect blood-pressure reading involving a pediatric patient. Cela alleged that these explanations were false and that the actual reason was her pregnancy.

Joint-employer allegations

The court held that Cela plausibly alleged that Della and the hospital were her joint employers. A joint employer is an entity that, although not the worker’s formal employer, exercises enough immediate control over the worker to share employment-law responsibility. Cela alleged that Della issued her an employee handbook, entered into an employment contract with her, recruited and hired her, and played a primary role in ending her employment. The contract also allegedly allowed either Della or the hospital to direct and supervise her.

The court also held that Cela plausibly alleged that Della knew or should have known about the discriminatory conduct and failed to take corrective action within its control. Della notified Cela of the termination and its stated reasons, refused her offer to show that she did not have long nails, and chose to terminate her rather than place her with another employer.

Discrimination and aiding-and-abetting claims

The court held that Cela plausibly alleged pregnancy discrimination under Title VII, the New York State Human Rights Law, and the New York City Human Rights Law. At the motion-to-dismiss stage, the court accepted the complaint’s factual allegations as true and considered whether they supported a reasonable inference of discrimination.

The court found relevant Cela’s allegations that the stated reasons for termination were pretextual: she alleged that she did not have long nails, had received positive feedback from trainers, and had not worked directly with patients. She also alleged that an unnamed hospital employee saw paperwork revealing her pregnancy on a supervisor’s desk and that another hospital employee believed she was terminated because of her pregnancy. Although the defendants received the medical-examination results before Cela began working, the court noted that the complaint did not establish when they reviewed the pregnancy information.

The court further held that Cela plausibly alleged an aiding-and-abetting claim against Della under the New York state and city human-rights laws. Those laws prohibit helping or participating in discriminatory conduct, and the court found that the allegations supporting Della’s role as a joint employer also plausibly showed that Della participated in the alleged discrimination.

State and city claims

Because Cela plausibly alleged a federal pregnancy-discrimination claim under Title VII, the court exercised supplemental jurisdiction over her New York State Human Rights Law and New York City Human Rights Law claims. Supplemental jurisdiction allows a federal court to hear related state-law claims alongside a federal claim.

Disposition

The court denied Defendants’ motions to dismiss. The defendants were ordered to file answers to the amended complaint within 21 days after the opinion and order. The ruling allowed the case to continue; it did not decide after trial or other merits proceedings whether Cela’s allegations were ultimately true.