Santamaria v. Vee Technologies, Inc.

Background

Toni Santamaria worked as Vee Technologies, Inc.’s human-resources director from April 2018 through August 2021. The parties disputed what her job involved. Defendants described her as exercising authority over recruiting, hiring and firing, company policies, employment issues, and compensation practices. Santamaria described herself as Sue Smith’s assistant, performing administrative tasks under Smith’s direction and without making hiring decisions.

Santamaria reported knee pain in January 2020. In July 2021, after Vee Technologies announced that employees were expected to return to the office twice a week, she asked Smith to let her continue working remotely because of her knee problems. She was terminated on August 26, 2021, after Smith and Patrick O’Malley learned that she had forwarded to her personal email an employee report that mistakenly contained restricted compensation information. Defendants said the termination was based on her handling of that information. Santamaria argued that the stated reason was a pretext and that she was actually fired because she requested an accommodation.

Her amended complaint asserted claims for unpaid overtime under the Fair Labor Standards Act and New York Labor Law; violations of New York’s Wage Theft Protection Act; and disability-related claims under the Americans with Disabilities Act, New York State Human Rights Law, and New York City Human Rights Law. Defendants moved for summary judgment, which asks whether the evidence leaves any real dispute about facts that could affect the outcome.

Failure to Accommodate

The court denied summary judgment on Santamaria’s failure-to-accommodate claims under the ADA, NYSHRL, and NYCHRL. Santamaria testified that her knee injury limited how far she could walk and caused pain after walking more than half a mile. The court held that a reasonable juror could find that the injury substantially limited walking, which is a major life activity covered by the ADA. The court also found a possible connection between the knee injury and her request to work from home.

Although Santamaria was working from home when she was terminated, the evidence did not establish whether this was an accommodation for her injury or merely part of Vee Technologies’ general transition back to the office. Santamaria said her request had not been approved or denied before her termination. The court therefore found factual disputes about whether defendants had provided the requested accommodation.

Discriminatory Treatment

The court denied summary judgment on Santamaria’s disability-discrimination claims. Defendants identified her handling of the restricted information as a legitimate, nondiscriminatory reason for the termination. But the court found disputes about whether Smith wanted Santamaria terminated because of her accommodation request and whether Smith influenced O’Malley’s decision.

The court also identified disputes about whether defendants genuinely viewed Santamaria’s conduct as serious enough to justify termination. Among other evidence, Santamaria argued that defendants did not take significant steps to recover the information, had previously given her access to similar information without taking action, and did not suffer a measurable penalty from the incident. O’Malley also gave deposition testimony suggesting confusion about what Santamaria had done wrong. The court concluded that these disputes could allow a reasonable factfinder to question whether defendants’ stated reason was a pretext for discrimination.

Interactive-Process Claims

The court granted summary judgment on Santamaria’s ADA and NYSHRL claims alleging failure to engage in an interactive process. The court explained that those statutes do not create an independent claim based only on an employer’s failure to participate properly in that process.

The court denied summary judgment on the corresponding NYCHRL claim. Under the New York City law, failure to engage in the interactive process can be independently actionable. Because Santamaria told Smith about her injury and accommodation request, was terminated before the request was resolved, and presented evidence creating factual disputes about disability-related motivation, the court found factual disputes about whether defendants engaged in the required process.

Overtime Claims

The court denied summary judgment on Santamaria’s overtime claims. Defendants argued that she was covered by the administrative exemption under the FLSA and NYLL. The exemption applies when an employee is paid at least the required salary, performs office or nonmanual work related to business operations, and primarily exercises discretion and independent judgment on significant matters.

The court found that Santamaria met the salary and business-operations requirements. The remaining question—whether exercising discretion and independent judgment was part of her primary duty—was fact-intensive. Defendants cited Santamaria’s résumé, LinkedIn description, and emails showing involvement in human-resources planning and hiring. Santamaria, however, testified that Smith micromanaged her work and that she spent about 80 percent of her time on administrative tasks. Because a reasonable juror could find that those tasks did not involve significant discretion, summary judgment was inappropriate.

Wage Statements and Notices

The court also otherwise denied defendants’ motion on Santamaria’s Wage Theft Protection Act claims. Defendants argued that Santamaria lacked the concrete injury required to bring those claims in federal court because she had not shown harm from allegedly inaccurate or missing wage information.

Santamaria responded that she was misclassified as exempt and therefore was not told that she could receive overtime pay. She claimed that this lack of information contributed to her not receiving overtime. The court found that this alleged injury could satisfy the requirement of a concrete harm, particularly because factual disputes existed about whether she was misclassified and was entitled to overtime. The court also noted that the required notice includes an employee’s overtime rate, which Santamaria would not have received if she was misclassified.

Disposition

The court’s conclusion states that defendants’ motion was granted as to Santamaria’s interactive-process claims under the ADA and NYSHRL and otherwise denied. The court directed the parties to file a joint letter by March 29, 2024, stating their availability for trial in May or June 2024, and directed the clerk to terminate docket entry 42.